HomeMy WebLinkAboutCMR 254-09 (1)TO: HONORABLE CITY COUNCIL
FROM: CITY MANAGER DEPARTMENT: CITY MANAGER'S OFFICE
DATE: MAY 18,2009 CMR: 254:09
REPORT TYPE: REPORTS OF OFFICIALS
SUBJECT: . Adoption of a Mitigated Negative Declaration and the Foothills Fire
Management Plan
RECOMMENDATION
Staff recommends that the City Council adopt the Mitigated Negative Declaration ("MND"),
dated February 9, 2009, and the attached Foothills Fire Management Plan ("Plan"), dated
January 15,2009.
BACKGROUND
The City first prepared and adopted a Foothills Fire Management Plan in 1982. The City'S
consultants have prepared an updated Foothills Fire Management Plan, in response to Council
direction to staff and in response to changes in the Foothills, laws and regulations, and input
from residents, neighboring jurisdictions, and other community members.
The Plan incorporates lessons learned from the Oakland Hills Fire of 1991 and other best
practices, including working collaboratively with neighboring jurisdictions, police and fire
agencies, and community partners.
The objectives driving the recommendations in the Plan are:
• Life Safety
• Structure and Infrastructure Protection
• Ignition Prevention
• Fire Containment
• Natural Resource Protection and Enhancement
CMR: 254:09 Page 1 of 10
The components of the Plan are:
• Fire Hazard Assessment: The consultant conducted a fire science review of fuel types,
loads, topography, and other factors. The data were analyzed with various computer
models and correlated on maps.
• Regional Evacuation: The consultant surveyed 19 miles of City roadways, 12 miles of
which are identified as critical evacuation routes, and most of which have prolongations
or feed other road systems outside the City limits.
• Review of Municipal Ordinances: The consultant found most City Municipal Codes
related to the Foothills are adequate. Several updates were suggested.
• Staffing of Fire Station 8: The consultant analyzed objectives and resources for response
to fires in the Foothills. The recommendation in the Plan is to maintain current staffing
levels for Fire Station 8 (~$200,000 in staff overtime and ancillary costs). Police officers
(directed patrol) and Open Space Ranger staffing may need to be increased during high-
risk conditions (viz., Red Flag).
• Wildland Fire Management Recommendations and Mitigations: The consultant presents
specified fire prevention treatments on City-owned lands and roads. An outside
environmental consultant (TRA Environmental Sciences, Inc.) supplemented the
evaluation of and incorporation into the Plan of best practices for recommended
treatments.
• Updates to Pearson-Arastradero Trails Master Plan and Foothills Trail Maintenance Plan:
The consultant reviewed existing Plans and suggested updates.
• CEQA Documentation: The consultant worked with the Planning Department and TRA
Environmental Sciences, Inc. to develop the MND.
• Implementation Plan and Potential Funding: The Plan presents an overview of funding
strategies. The total five-year cost, beyond what the City currently spends, to implement
the recommended projects is estimated at approximately $435,000. This report will not
include a plan to address the funding implications of the recommendations. Staff will
return to the Council at a later date with funding plan recommendations along with other
implementation measures.
While the nominal title of the Plan is fire management, the Plan necessarily includes law
enforcement (evacuation, crime in the area, notification/warning and emergency public
information, Block Preparedness Coordinator Program), natural resource management (Ranger
staff), utilities (power lines, water supply, and related infrastructure), public works, and other
topics.
DISCUSSION
This new Plan would replace the existing Foothills Fire Management Plan, dated 1982. The City
retained Wildland Resource Management (Carol Rice) as the primary consultant to develop this
updated Plan, working with staff from the City Manager's Office, the Open Space Park Rangers,
the Fire Department, the Police Department, and other work groups.
CMR: 254:09 Page 2 oflO
Scope and Geography
The Foothills are defined in the Fire Management Plan as lands on and to the west of Foothill
Expressway and Junipero Serra Boulevard to the City limits on Skyline Boulevard.
The focus of the Plan is on lands owned by the City and roadways, since the City has
responsibility and direct control over such areas. The Plan identifies 51 areas where treatments
are to be conducted. These treatment areas are found within Foothills Park, Pearson-Arastradero
Preserve, and 12 miles of City roadways.
The Plan also notes that the Foothills area includes a wide range of lands, buildings, and
resources, such as:
• Open Space and Parks: In addition to the City-managed Foothills Park and Pearson-
Arastradero Preserve, there are other open space areas in the area, including the
Montebello Open Space Preserve and the Los Trancos Open Space Preserve (managed by
the Midpeninsula Open Space District).
• Private Residences: There are roughly 200 homes in the City limits and hundreds more
abutting or near the Palo Alto Foothills in neighboring jurisdictions in both San Mateo
County and Santa Clara County.
• Private Recreation Facilities: There are several private equestrian, golf, sports complexes
in the Foothills.
• Commercial Buildings: There are millions of square feet of commercial and industrial
buildings in the Foothills (Stanford Industrial Park).
• Stanford University: Stanford holds substantial lands in the Foothills. These have a direct
nexus to the City for police and fire services. The Palo Alto Fire Department provides
service to Stanford University under contract, including the Stanford Linear Accelerator
(SLAC) in San Mateo County. The Palo Alto Police Department, in addition to
providing primary response coverage to large portions of Stanford lands as well as
mutual aid, provides 911 dispatch of the Stanford Department of Public Safety (Stanford
Police) under contract.
Outreach and Regional Cooperation
The City should not and cannot plan or operate in isolation regarding the Foothills. The nature
of jurisdictional boundaries, interrelationships, and inter-agency cooperation (mutual aid), as
well as a specific goal to include non-governmental organizations in the planning process,
resulted in three formal outreach sessions to the general public, a Council presentation in
October 2008, a presentation to the Parks and Recreation Commission, and numerous other
meetings with our neighbors, including, but not limited to:
• Acterra
• CALFIRE
• Friends of Foothills Park
• Los Altos Hills Fire District
• Los Trancos County Water District
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• Los Trancos Woods Neighborhood
• Menlo Park Fire District (including the Town of Atherton, City of Menlo Park, City of
East Palo Alto)
• Midpeninsula Regional Open Space District (MROSD)
• P A Protect Our Open Space
• Palo Alto Hills Neighborhood Association
• Pony Tracks Ranch
• Portola Pasture Stables
• San Mateo County FireSafe Council
• San Mateo County Sheriff
• Santa Clara County Fire Dept
• South Skyline Association
• Stanford Community Residential Leaseholders (SCRL)
• Stanford University
• Town of Los Altos Hills
• Vista Verde Community Association
• Woodside Fire Protection District
This outreach was not bounded merely by the need to collect opinions for the Plan. One key
recommendation of the Plan is to form an ongoing working relationship with these neighbors, to
increase the overall resilience of the Foothills against fires, natural disasters, crime, and other
threats. The Plan recommends that the City continue and expand this collaboration.
Similarly, the topic of evacuation necessitates inter-agency and private-public partnerships.
While the Palo Alto Police Department is the lead agency' for evacuation planning and
operations, other jurisdictions must coordinate in these processes. The Plan calls for the creation
of a regional evacuation and response system for the Foothills: "Foothills Regional Emergency
Response and Evacuation Plan (FREREP)." This plan would provide for standardized signage
and evacuation route nomenclature and protocols. The Block Preparedness Coordinator (BPC)
Program will be an integral component, as residents who are BPCs can open gates and serve as
"eyes and ears" for first responders. The FREREP would also facilitate an "all hazards"
approach, covering crime prevention, missing persons (lost child or person at-risk), and other
issues affecting the Foothills region.
Wildland Fire Management Recommendations and Mitigations
There are approximately 330 acres of City land (out of approximately 2,000 acres) that are
recommended to undergo some level of fire mitigation treatments. Such treatments will follow
best management practices to reduce deleterious environmental impacts. In many cases,
treatments can actually enhance resources (removal of non-native, invasive species).
During the outreach meetings, staff found that many neighbors and residents did not have a clear
understanding that "treatment" does not mean "clear cutting" or the removal of all flora and
fauna. In reality, the reduction of fuel-load and methods to contain fires allows for the park-like
aesthetic of the area to remain.
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Furthermore, certain current fire prevention treatments will be curtailed or eliminated.
Treatments will also be staggered; not all 330 acres will be treated in a given year. While the
total acreage under treatment is to increase from the current approximately 200 acres, the total
acreage treated in a given one year period will decrease (in most cases, only 100 acres would be
treated annually, according to the Plan, p. 46). For example, the City already performs annual
weed abatement, mowing, and other fuel-load-reduction actions. The Plan now provides that
some such treatments can be done on a rotational basis on up to five year intervals, as opposed to
every year.
Some areas will no longer be treated for fuel reduction (e.g., Madrone and Valley View fire
roads in Foothills Park), since they are not tied to the objectives of the Plan.
Implementation Plan
The Plan presents a general framework to guide the City in planning and allocating resources to
the Foothills. Staff is developing a Work Plan to implement the recommendations.
At this point, since funding has not yet been identified, the Work Plan is constrained to elements
that do not require substantial resources outside of existing budgets.
Staff is working with Wildland Resource Management to investigate government grants,
volunteer programs, Fire Safe Council funds, and other external means of financing or offsetting
. costs.
Any field activities (treatments) will be prioritized by their relation to life safety: fuel breaks,
evacuation routes, perimeter treatments, and defensible space.
However, several elements of the Work Plan do not require substantial funding (or can be
performed at a slower rate using existing resources). Some of these elements include:
• Use this Plan as the foundation for the proposed Foothills Regional Emergency Response
and Evacuation Plan (FREREP)
• Create Midpeninsula Foothills Emergency Forum (MFEF)
• Municipal Code updates
• Explore cooperative funding strategies: cost-sharing (or staff/resource sharing) with
neighboring agencies (Los Altos Hills, Cal Trans, Woodside Fire Prot. Dist., etc.)
• Update Geographic Information System (GIS) (new map layers/inputs from consultants)
• Special Patrols (by Fire, Police, Rangers) during times of heightened risk (Red Flag, Fire
Weather)
• Conduct training, meetings, and drills for Block Preparedness Coordinators for
neighborhood communication
• Revise Trail Plans for Pearson-Arastradero Preserve & Foothills Park
• Volunteer Program: develop plan for use of volunteers for treatment (perhaps thorugh
Acterra, Fire Safe Council, etc.)
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• Educate and work with adjacent landowners (homeowners and businesses) to reduce
hazards and improve coordination
• Develop Joint Information Center (nC): work with neighboring jurisdictions to ensure
that emergency public information (EPI) is co.ordinated. Training for Public Information
Officers (PIOs) and other staff on: Community Alerting and Notification System
(CANS), evacuation, KZSU 90.1 FM radio, the Emergency Alert System (EAS), etc.
• Include Plan in the City Emergency Operations Plan (EOP)
Staff will continue to develop the Work Plan and adapt it, based on funding and staffing
strictures.
RESOURCE IMPACT
The total five-year cost to implement the recommended projects is estimated at slightly less than
$700,000. Staff estimates that approximately $53,000 is currently spent annually for current
treatments, which is $265,000 over five years, so net new funding required may be
approximately $435,000.
The largest cost, at slightly more than $400,000, is to manage 19 fire containment areas. The
initial treatment for segments of major evacuation routes is estimated to cost about $192,960.
To implement and maintain the policies and procedures recommended in the Plan, supplemental
staff time will be required from the:
• City Manager's Office
• Open Space Park Rangers
• Fire Department
• Police Department
• City volunteers
Please refer to Section 5.4 of the Plan for the consultant's discussion of funding strategies.
POLICY IMPLICATIONS
Approval of this Plan is consistent with current City policies and regulations regarding fire
prevention, evacuation, and related matters.
This Plan also supports the three Council priorities of Environmental Protection, Economic
Health of the City (e.g., protecting private business facilities as well as critical utilities), and
Civic Engagement for the Common Good (e.g., partnership with neighborhoods and the Block
Preparedness Coordinator Program).
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ENVIRONMENTAL REVIEW
This Plan is a project subject to review under the California Environmental Quality Act (CEQ A).
A Mitigated Negative Declaration (February 9, 2009) was prepared and circulated for public
comment from February 10, 2009, through March 11, 2009. The City has concluded that any
adverse environmental impacts of the treatments proposed in the Plan can be fully mitigated to
protect against any potential negative environmental impacts.
The City retained the services of TRA Environmental Sciences, Inc., an independent biology and
ecology consulting firm. This firm was also previously involved in the preparation and
environmental review of the Foothills Park Trail Maintenance Plan (2004) and the Pearson-
Arastradero Trail Management Plan (2001). TRA completed a full analysis of potential impacts
to plants, animals, and other natural resources, and concluded that potential impacts could be
adequately mitigated through implementation of best practices and mitigation measures which
were incorporated into the MND.
Recommended best practices and mitigation measures include:
• Site inventory prior to treatment to determine the location of sensitive sites. Exploration
into the use of knowledgeable volunteers to conduct a more detailed, site-wide survey is
warranted.
• Site planning and design to determine specific vegetation treatment actions based on fire
management benefits, environmental impact, and required mitigation activities.
• Protection during vegetation treatment using best management practices tailored to
impacted sensitive resources.
• Protection of disturbed environmentally sensitive areas following either specific fire
management actions.
• Prior to any treatment being started, a qualified biologist (or trained staff expert) shall
work with personnel involved "regarding protected species and habitats in the project
area, the limitations on areas that can be accessed on foot or with equipment, and the
legal consequences of take of protected species or habitat." (Mitigated Negative
Declaration (February 9, 2009), BIO-I, p. 2.) This recommendation is consistent with the
approach adopted for trail improvements or maintenance as outlined in the Council-
adopted Foothills Maintenance Plan (2004) and Arastradero Trail Management Plan
(2001).
While there are a myriad of sensitive plants, animals, and other resources in the Foothills area,
the treatment areas do not necessarily impinge upon all types. For example, according to the
Biological Impact Assessment (January 8, 2009), "There are no Palo Alto-designated heritage
trees in the Foothills Fire Management Plan Update area." (p. 22)
Sensitive environmental areas and habitats, in general, tend to be outside the priority treatment
areas: 1) evacuation routes and 2) around buildings and certain public safety infrastructure.
During the CEQA Public Comment Period, the City received comments from the public via
letters, e-mail messages, and the City's web site. The Parks and Recreation Commission also
provided comments at their February 24 meeting.
CMR: 254:09 Page 7 aflO
Key issues and concerns include the following:
1) Concern that the proposed measures may degrade the visual character of the
area
The City received public comments expressing concern that treatments would
unreasonably alter the appearance of the park and preserve lands.
There will be localized changes to the treatment areas: near roadsides, structures, and
along Trappers Ridge.
The changes along roadsides will be:
• Mowed grass, creating a more uniform, tended, look
• Shrubs under trees will be removed, creating a more open and park-like
appearance. Views will extend further back from the roadside where topography
of vegetation does not block the view.
However, changes resulting from treatments will not adversely affect the visual character
of the area:
• Non-native plants are targeted for removal.
• Native trees will not be cut down, in most cases, but will be "limbed up," meaning
that lower branches will be trimmed to 8-feet height (or 1/3rd the height of short
trees).
• Views will extend farther back from the roadside, as foliage is trimmed back.
In some cases, there will be more foliage. For example, the appearance of Trappers Ridge
will change. Less will be mowed each year, with more grass allowed to grow along the
ridge. The visitor will see more groups (or clumps) of shrubs in grass where either
continuous grass or continuous shrubs now exist.
Vegetation around structures will be managed to a greater extent. The structure may be
more visible as shrubs are reduced in volume and lower branches of trees trimmed within
100 feet of the structure. Grass will be mowed within 30 feet of the structure, creating a
more tended appearance. Such treatments are required by law.
2) Concern that treatment measures could result in more weedy plants and patches
and create "increased fodder" for fires
Treatments call for targeting removal of weedy plants within the management areas.
Much of the mowing or grazing currently performed or done in the recent past in
Pearson-Arastradero Preserve was, in fact, done at the request of Acterra in order to
reduce the weedy plants and patches. Management of timing and techniques will be
employed to provide a competitive edge to native plants at the detriment of weeds.
Mitigation measures and best practices will be utilized to prevent any significant adverse
impact to habitats, plants or animals.
CMR: 254:09 80[10
Some plants that grow after the management has been performed can take advantage of
the reduced competition. They grow later in the spring and during the summer. They
may create more volume for a fire to bum, in some limited areas, but they also have a
short window of conditions under which ignition can occur. Such fuels may have the
potential to move rapidly, but have low flame lengths, meaning they are easier to
extinguish, compared to the fuel types and loads currently in those areas.
3) Concern that treatments will create increased erosion and negative impacts to
hillside habitats
Actions to prevent erosion are called for in the ten listed mitigation measures that will
take place in conjunction with the fuel management work. These measures include
avoiding sensitive sites and operation when the soil is wet. Hillside habitats are
maintained using best management practices used for other treatments, such as creating
islands to prevent fire spread without adverse impact to flora and fauna in the area.
Best practices also limit the creation of bare soiL In cases where such soil is exposed,
staff will deploy measures to confine erosion.
Work is also to be done along the roadside. In areas where erosion is possible from
mechanized vehicles, heavy equipment is limited to work on the road surface only, with
cutting performed by an articulated arm that does not cause accelerated erosion.
4) Concern that fire management may conflict with City plans and park
designations
Fuel management is already routinely conducted in both Foothills Park and Pearson-
Arastradero Preserve and has been done for many years. The trails plans for each of the
areas allow for work to be done to maintain public safety. For example, the Foothills
Park Trails Maintenance Plan (January 29, 2002) identifies fuel breaks as part of the
maintenance regimen.
Best management practices to promote native vegetation are encouraged under current
planning documents for both landholdings.
Current codes and regulations require fuel management adjacent to roads, structures,
barbeques and other locations. This work is not discretionary. Sections 4290 and 4291
of the California Public Resources Code, for example, mandate Defensible Space be
established for structures in the Foothills. Parks and preserves are not exempt from such
laws.
5) Concern that stream banks in Wild Horse Valley may not remain stable if
shrubs are removed
Shrubs will be trimmed back, but their roots will not be removed. The cutting operation
will not necessarily involve soil surface disturbance. Shrub removal will result in a
regrowth of the shrubs and new growth of grasses within months (see above for erosion
CMR: 254:09 Page 9 of 10
control methods). The shrubs roots that provide soil stability are not disturbed. The new
cover of grass foliage offers raindrop splash protection and grass roots offer greater
surface soil holding capacity.
Additionally, Mitigation Measure Geology 6 requires a buffer of 25-50 feet be
maintained between operations and water bodies or designated riparian areas. Rainwater
run-off barriers will be installed and managed in all treatment and operating areas.
ATTACHMENTS
Attachment A: Palo Alto Foothills Fire Management Plan Update (Draft, January 15, 2009)
Attachment B:
Attachment C:
Attachment D:
Attachment E:
PREPARED BY:
Mitigated Negative Declaration (February 9,2009)
Biological Impact Assessment (January 8, 2009)
Public Comments (various from web site, e-mail, letter, etc.)
Minutes of the Parks and Recreation Commission, Feb. 24, 2009
KELLY MORARIU
Interim Deputy City Manager
lIif!J 11£
· ~
NIC MARIN RO
Interim DIrector
CffJunity Services Department ·lL~~
OFFICER KENNETH DUEKER
Coordinator, Homeland Security
Palo Alto Police Department
Assigned to the City Manager's Office
CITY MANAGER APPROVAL:
CMR: 254:09 Page 10 of 10
Palo Alto Foothills Fire Management Plan
Update
WILDLAND FIRE RISK ASSESSMENT AND MITIGATION PROGRAM
DRAFT
Submitted to:
City of Palo Alto
Attention: Kelly Morariu
250 Hamilton Avenue
Palo Alto, CA 94301
Submitted by:
Wildland Resource Management, Inc.
Wildland Resource Management
134 Journeys End
Alamo, CA 94507
January 15, 2009
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 2
TABLE OF CONTENTS
Part A - FIRE HAZARD ASSESSMENT AND FUEL MANAGEMENT PLAN/ PROJECTS
1 Executive Summary .................................................................................................................................................................. 8
2 Introduction ............................................................................................................................................................................ 12
2.1 Goals and Objectives .................................................................................................................................................... 13
2.2 Planning History ........................................................................................................................................................... 14
2.3 Scope of the Plan .......................................................................................................................................................... 17
2.4 Planning Process ........................................................................................................................................................... 17
3 Existing Conditions................................................................................................................................................................. 19
3.1 Fire Hazard ................................................................................................................................................................... 19
3.1.1 Vegetation and Fire Fuels ................................................................................................................................. 19
3.1.2 Fire Behavior .................................................................................................................................................... 21
3.1.2.1 Fire Behavior Modeling .......................................................................................................................... 21
3.1.2.2 Spatial Input Files ................................................................................................................................... 21
3.1.2.3 User-Defined Inputs ................................................................................................................................ 22
3.1.2.4 FlamMap Results .................................................................................................................................... 23
3.2 Fire Suppression Capabilities ........................................................................................................................................ 27
3.3 Access ........................................................................................................................................................................... 28
3.4 Sensitive Resources ...................................................................................................................................................... 28
3.4.1 Social and Cultural Features ............................................................................................................................. 31
3.4.2 Environmental Features .................................................................................................................................... 31
3.4.2.1 Species and Wildlife ............................................................................................................................... 32
3.4.2.2 Soils and Geology ................................................................................................................................... 37
4 Fuel Management in City Parks .............................................................................................................................................. 39
4.1 Identifying Potential Treatment Areas .......................................................................................................................... 39
4.2 Establishing Project Objectives .................................................................................................................................... 39
4.3 Current Fuel Management Program .............................................................................................................................. 41
4.4 Project Description........................................................................................................................................................ 46
4.4.1 Scope of Recommended Fuel Management Projects ........................................................................................ 46
4.4.2 Project Description Summary ........................................................................................................................... 46
4.4.3 Project Objectives ............................................................................................................................................. 46
4.4.4 Priority .............................................................................................................................................................. 47
4.4.5 Project Locations............................................................................................................................................... 47
4.4.6 Project Dimensions and Post-Treatment Standards ........................................................................................... 53
4.4.7 Roadside and Driveway Fuel Modification for Safe Access and Egress ........................................................... 54
4.4.7.1 Specific Goal of Action ........................................................................................................................... 54
4.4.7.2 Location and Description of Projects ...................................................................................................... 54
4.4.8 Fuel Modification for Firefighter Safety Projects ............................................................................................. 57
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 3
4.4.8.1 Specific Goal of Action ........................................................................................................................... 57
4.4.8.2 Location and Description of Projects ...................................................................................................... 57
4.4.9 Structure and Infrastructure Projects – Defensible Space ................................................................................. 57
4.4.9.1 Specific Goal of Action ........................................................................................................................... 57
4.4.9.2 Location and Description of Projects ...................................................................................................... 58
4.4.10 Ignition Prevention Fuel Management Projects ................................................................................................ 59
4.4.10.1 Specific Goal of Action ........................................................................................................................... 59
4.4.10.2 Location and Description of Projects ...................................................................................................... 59
4.4.11 Fuel Modification for Containment Ease .......................................................................................................... 59
4.4.11.1 Specific Goal of Action ........................................................................................................................... 59
4.4.11.2 Location and Description of Projects ...................................................................................................... 60
4.4.12 Fuel Modification for Ecosystem Health .......................................................................................................... 62
4.4.12.1 Specific Goal of Action ........................................................................................................................... 62
4.4.12.2 Location and Description of Projects ...................................................................................................... 62
4.4.13 Cooperative Fuel Management Projects for Offsite Fire Containment and Evacuation Ease ........................... 63
4.4.13.1 Specific Goal of Action ........................................................................................................................... 63
4.4.13.2 Location and Description of Projects ...................................................................................................... 63
5 Implementation Plan ............................................................................................................................................................... 64
5.1 Implementation Strategies ............................................................................................................................................. 64
5.2 Priorities ........................................................................................................................................................................ 65
5.3 Fuel Management Project Costs .................................................................................................................................... 66
5.3.1 Project Cost Estimates....................................................................................................................................... 67
5.4 Funding Strategies to Support Fuel Management ......................................................................................................... 71
5.5 Grant Opportunities ...................................................................................................................................................... 72
6 Treatment Standards and Methods .......................................................................................................................................... 74
6.1 Treatment Standards for Vegetation Types ................................................................................................................... 74
6.1.1 Prescription for Grasslands ............................................................................................................................... 74
6.1.2 Prescription for North Coastal Scrub and Chaparral ......................................................................................... 74
6.1.3 Prescription for Oak Woodlands ....................................................................................................................... 76
6.1.4 Prescription for Riparian Forest ........................................................................................................................ 76
6.1.5 Defensible Space Guidelines ............................................................................................................................. 77
6.2 Description of Treatment Methods ............................................................................................................................... 78
6.2.1 Summary ........................................................................................................................................................... 78
6.2.2 Timing of Treatments ........................................................................................................................................ 78
6.2.3 Hand Labor ....................................................................................................................................................... 79
6.2.4 Mechanical Treatments ..................................................................................................................................... 79
6.2.5 Grazing with Sheep and Goats .......................................................................................................................... 81
6.2.6 Broadcast Prescribed Burns .............................................................................................................................. 81
6.2.7 Eucalyptus Tree Removal ................................................................................................................................. 82
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 4
6.2.8 Herbicide Application to Control Invasive Plants ............................................................................................. 83
6.3 Best Management Practices .......................................................................................................................................... 84
6.3.1 Hand Labor ....................................................................................................................................................... 84
6.3.2 Mechanical Treatments ..................................................................................................................................... 85
6.3.3 Grazing with Sheep and Goats .......................................................................................................................... 86
6.3.4 Broadcast Prescribed Burns .............................................................................................................................. 86
6.3.5 Herbicide Application ....................................................................................................................................... 87
P ART B – PO L I C Y REVIEW AND SUPPLEMENTAL RECOMMENDATIONS
1 Evacuation and Refuge ........................................................................................................................................................... 89
1.1 Identification and Notification ...................................................................................................................................... 89
1.2 Regional Cooperation ................................................................................................................................................... 90
1.3 Temporary Refuge ........................................................................................................................................................ 90
2 Codes and Regulations ............................................................................................................................................................ 91
2.1 Existing Codes and Ordinances .................................................................................................................................... 91
2.1.1 Fire Code ........................................................................................................................................................... 91
2.1.2 Building Code ................................................................................................................................................... 93
2.2 Recommendations ......................................................................................................................................................... 93
2.3 Exterior Hazard Abatement .......................................................................................................................................... 95
2.3.1 For parcels of land one acre or less maintain parcel in complete abatement. .................................................... 95
2.3.2 For parcels larger than one acre in size ............................................................................................................. 96
3 Fire Protection – Station 8 ...................................................................................................................................................... 98
3.1 Description .................................................................................................................................................................... 98
3.2 Appraisal ....................................................................................................................................................................... 99
3.3 Recommendation ........................................................................................................................................................ 100
4 Trail Plan Update .................................................................................................................................................................. 101
4.1 Pearson-Arastradero Preserve Trails Management Plan (March 2001) ...................................................................... 101
4.1.1 Recommended Revisions ................................................................................................................................ 101
4.1.2 Existing Fire Mitigation and Fuel Management in the Arastradero Trails Management Plan ........................ 103
4.1.3 Vegetation Management ................................................................................................................................. 107
4.1.3.1 Brushing and Clearing Defined ............................................................................................................. 107
4.1.3.2 Techniques for Maintaining a Clear Passageway .................................................................................. 107
4.2 Foothills Park Trails Maintenance Plan (January 29, 2002) ....................................................................................... 109
4.2.1 Recommended Revisions ................................................................................................................................ 109
4.2.2 Existing Fire Mitigation and Fuel Management in the Foothills Park Trails Maintenance Plan ..................... 110
5 References ............................................................................................................................................................................ 113
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 5
LIST OF FIGURES
Figure 1: City of Palo Alto Overview. ............................................................................................................................................ 12
Figure 2: 1997 Fire Management Zones. ........................................................................................................................................ 16
Figure 3: Wildland Surface Fuels. .................................................................................................................................................. 20
Figure 4: Spatial Data Required for Fire Behavior Modeling. ........................................................................................................ 22
Figure 5: Comparison of Torching and Active Crown Fire. ........................................................................................................... 23
Figure 6: Crown Fire and Torching Potential. ................................................................................................................................ 24
Figure 7: Predicted Flame Length................................................................................................................................................... 25
Figure 8: Predicted Rate of Spread. ................................................................................................................................................ 26
Figure 9: Locations of Cultural and Environmental Sensitive Resources in Pearson-Arastradero Preserve. .................................. 29
Figure 10: Locations of Cultural and Environmental Sensitive Resources in Foothills Park. ........................................................ 30
Figure 11: Sensitive Species Known or Potentially Occurring in Foothills Park or Pearson-Arastradero Preserve. ...................... 37
Figure 12: Soil Types in Foothills Park and Pearson-Arastradero Preserve. .................................................................................. 38
Figure 13: Project Goals and Actions. ........................................................................................................................................... 40
Figure 14: Pearson-Arastradero Preserve Current Fuel Management Areas. .................................................................................. 42
Figure 15: Foothills Park Current Fuel Management Areas. .......................................................................................................... 43
Figure 16: Recent Treatments in Pearson-Arastradero Preserve. .................................................................................................... 44
Figure 17: Recent Treatments in Foothills Park. ............................................................................................................................ 45
Figure 18: Listing of Project Locations. ......................................................................................................................................... 50
Figure 19: Proposed Treatment Locations in Pearson-Arastradero Preserve. ................................................................................. 51
Figure 20: Proposed Treatment Locations in Foothills Park. .......................................................................................................... 52
Figure 21: Treatment Methods and Intervals. ................................................................................................................................. 53
Figure 22: Listing of Project Locations for Evacuation and Access. .............................................................................................. 55
Figure 23: Evacuation Routes External to Foothills Park and Pearson-Arastradero Preserve. ....................................................... 56
Figure 24: Listing of Project Locations for Fire Fighter Safety Fuel Modification. ....................................................................... 57
Figure 25: Listing of Project Locations for Defensible Space. ....................................................................................................... 59
Figure 26: Listing of Project Locations for Ignition Prevention. .................................................................................................... 59
Figure 27: Listing of Project Locations for Containment Ease. ...................................................................................................... 61
Figure 28: Listing of Project Locations for Ecosystem Health. ...................................................................................................... 62
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Figure 29: Unit Costs for Fuel Reduction Treatment Methods. ...................................................................................................... 67
Figure 30: Funding Mechanisms. ................................................................................................................................................... 71
Figure 31: Initial Priority of Removal for Brush. ........................................................................................................................... 76
Figure 32: Pruning Example. .......................................................................................................................................................... 77
Figure 33: Pruning Example. .......................................................................................................................................................... 95
Figure 34: Shrub Spacing. .............................................................................................................................................................. 96
Figure 35: Fire Protection Resources. ............................................................................................................................................. 98
Figure 36: Emergency/Maintenance Access Points. ..................................................................................................................... 102
Figure 37: Vehicle Turn-around Design Summary. ...................................................................................................................... 109
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PART A – FIRE HAZARD ASSESSMENT AND FUEL
MANAGEMENT PLAN/ PROJECTS
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1 EXECUTIVE SUMMARY
The Fire Management Plan update process addresses a broad range of integrated activities and planning
documents to address and mitigate the impacts of fire hazards in the Palo Alto Foothills Area. The area of interest includes the areas west of Foothills Expressway to the city limits of Palo Alto. Fire mitigation project
areas include the boundaries of Foothills Park and Pearson-Arastradero Preserve within this area of interest.
The Fire Management Plan Update addresses the following key items:
• Fire Hazard Assessment
• Regional Evacuation Routes
• Review of Municipal Ordinances
• Staffing of Station 8
• Wildland Fire Management Recommendations and Mitigations
• Updates to Pearson-Arastradero Trails Master Plan and Foothills Trail Maintenance Plan
• CEQA Documentation
• Implementation Plan and Potential Funding
Community Participation. Community participation in the development of the plan began with the refinement of the scope of work and selection of the consultant team. Three community meetings were held at key points in the planning process to gather continued input from the community. A stakeholder group
made up of adjacent jurisdictions, neighborhood associations, special interest groups, volunteers etc. also
participated in the planning process. An environmental review in accordance with the California Environmental Quality Act (CEQA) was undertaken by City Staff in conjunction with the plan development.
Fire Hazard Assessment. There are many ways to assess fire hazard. Most utilize the three main factors of
fuels, weather, and topography, with possible inclusion of elevation or fire history. Fire behavior was chosen
as the means to assess fire hazard since it can identify locations where containment may be easiest, and where access may be precluded during the time of a fire. In addition, fire behavior outputs can identify locations where structures or natural resources may be unduly harmed by a wildfire, as well as locations where fire
effects may be inconsequential to natural resources.
Not every area identified as a potential fire hazard can be modified to produce low-intensity fires. Not only would this be too costly, but environmental impacts would also be unacceptable.
Results of Fire Behavior Analysis. Fire behavior was analyzed for the entirety of the Foothills Area,
including adjacent neighborhoods, property owned by Midpeninsula Regional Open Space District
(MROSD), and Stanford University. Flame length, rate of fire spread and potential for crown fire were three characteristics considered in the analysis. The following are generalities observed:
Flame lengths follow fuel types, with long flame lengths in chaparral and untreated grass, and short flame
lengths in woodlands and mowed grass. The largest areas of long flames are located in Foothill Park and
Monte Bello Open Space Preserve. Low fire spread rates were predicted in woodlands and forests, and fast
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spread rates in untreated grass and chaparral. There is very little active crown fire predicted within the Foothills area, however, the potential for trees to torch is high throughout the treed portion of the Foothills area. Torching is caused by low-hanging limbs, or ladder fuels.
Wildland Fire Management Recommendations and Best Management Practices
Treatments were strategically placed to achieve the following goals:
• Life Safety
• Structure and Infrastructure Protection
• Ignition Prevention
• Fire Containment
• Resource Enhancement
Treatments were identified for 51 project areas. The most visible recommended set of projects will be to
conduct roadside treatments along Page Mill Road, Arastradero Road, Los Trancos Road, and Skyline Boulevard. Other projects entail the continuation of mowing along trails and some boundaries, grazing along the selected segments of the perimeter of both Parks/Preserves, treatments to install and maintain defensible
space around structures, treatments around barbeques to minimize the chance of ignitions, and treatments to
bolster the success of fires containment efforts within the parks. Fuel management treatments can also enhance natural resources, through targeting non-native invasive plants as part of biomass removal –
potentially with grazing animals, mechanical mowing and hand labor - and conducting prescribed fires in
selected areas under conditions consistent with fire control.
Best management practices are included for each treatment type, based on the sensitivity of the resource. These include practices that consider the timing intensity of the treatment, or selection of the type of treatment
methods (e.g., whether the project would entail mowing or grazing, hand labor or mechanical equipment), the
strata of treatment (e.g., whether the project would remove lower tree limbs, or instead involve grass mowing), and the scale of the treatment (e.g., to treat small or large patches).
Review Recommendations Regarding Pearson-Arastradero Trails Master Plan and Foothills Trail
Management Plan
• Addition of fuel management and fuel reduction zones
• Location of prescribed burns
• Modify fuel break width for performance standards
• Modify roadside treatment standards
• Include fire hazard in regulatory, warning and education signs (especially prescribed fires)
Regional Evacuation Routes
The Palo Alto Police Department has responsibility within City limits for evacuation operations under state
law. However, multiple jurisdictions will likely be involved in an event in the Foothills. Evacuation routes
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should not be blocked anywhere, regardless of jurisdiction or ownership; this is especially important because most of the regional evacuation routes span multiple cities, ownership categories and protection jurisdictions. The following recommendations will help reach a reasonably safe condition along the regional evacuation
routes.
• Formalize agreements with adjacent landowners for ingress and egress routes (from parks) and offsite
refuge areas
• Develop partnerships to address regional evacuation routes from residential and public areas (Regional Evacuation Plan, Community Notification (multi-jurisdictional) and Unified Command)
Analysis and Recommendations Regarding Staffing of Station 8
An analysis of the staffing level of Station 8 was conducted that considered the distribution and concentration
of fire personnel and equipment in relation to the incidents. The recommendation was to maintain current staffing levels. Response times for incidents are significantly longer from other stations, even when
considering mutual aid offered by other jurisdictions. The fire behavior analysis indicates the potential for
fast-moving fires of high intensity, further justifying the current staffing levels.
Review of Municipal Ordinances
The existing code is comprehensive; only minor changes are recommended. These include:
• Expand Wildland Urban Interface Fire Area (between Foothill Blvd & Highway 280)
• Fire Protection Planning: Begin early in permitting process
• Expand Defensible Space Requirements: Maintain roof free of materials
• Expand Access Requirements: bridge load limits, parking restrictions
• Additional guidance for Maintenance of Defensible Space
• Ignition Source Control
• Fencing
• Signage
• Mechanical Equipment Ignition Prevention
• Restriction on Smoking at Pearson-Arastradero Preserve
Implementation Plan and Potential Funding for Fire Management Recommendations
Implementation of this plan will be managed by the City of Palo Alto staff, including the Fire Department, the
Police Department (evacuation, notification, neighborhood preparedness coordinators), and Open Space
(rangers). Volunteer groups, such as Acterra, Friends of Foothills, and other groups should continue to be involved and encouraged to help with the implementation. Further, the City should work with mutual aid
government agencies and other stakeholders on an ongoing basis.
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Prioritization of Treatments
The following is the priority of treatment types:
1. Life Safety
2. Structure and Infrastructure Protection
3. Ignition Prevention
4. Fire Containment
5. Resource Enhancement
Cost Estimates
The total five-year cost to implement the recommended projects is estimated at slightly less than $700,000.
The largest cost, at slightly more than $400,000, is to manage 19 containment areas. The initial treatment for segments of major evacuation routes is estimated to cost almost $178,000. The use of California Youth
Authority Crews may offer a means to reduce costs for the hand labor-based treatments. Without volunteers
pre-treatment surveys and follow-up may cost $100,000 over the next five years.
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2 INTRODUCTION
The Palo Alto Foothills consist of a mix of urban, semi-urban and open space lands on the eastern slope of the
Santa Cruz Mountains. Within the city limits of Palo Alto, the Palo Alto Foothills area west of the Foothills
Expressway and Junipero Serra Boulevard represents a Wildland Urban Interface area (WUI) with significant
impacts to public safety, cultural and economic activities, and environmental and natural resource management. The Palo Alto Foothills Area includes two city-managed areas: Foothills Park and the Pearson-
Arastradero Preserve. In an effort to implement an updated Fire Management program for the Foothills, the
City of Palo Alto conducted a review of the fire hazards, mitigation activities, and environmental considerations for the area to develop recommendations for wildland fuels and fire management.
Figure 1: City of Palo Alto Overview.
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2.1 Goals and Objectives
The City of Palo Alto developed, maintains, and executes a Fire Management Plan focused on reducing losses
from wildland fire. In support of this long-term objective, the City of Palo Alto initiated an update process
for the Foothills Fire Management Plan to prepare recommendations for consideration and possible inclusion in future budgets.
This Foothills Fire Management Plan update process focused on the three primary goals:
• Develop recommendations for wildland fuels and fire management to reduce fire hazard in Palo Alto’s Wildland Urban Interface west of Foothill Expressway to an acceptable level of risk.
o Review and incorporate the 1982 Foothills Fire Management Plan and 1997 staff update.
o Identify appropriate management recommendations to reduce wildland fuel loads in the Pearson-Arastradero Preserve and Foothill Park.
• Maintain ecological and aesthetic values of Foothill Park and Pearson-Arastradero Preserve
consistent with fire reduction goals.
• Provide a fuel management plan for Foothills Park and Pearson-Arastradero Preserve that is cost
effective and sustainable for the City of Palo Alto.
The Fire Management Plan update process involved a combination of City staff personnel from a wide cross section of city operations, stakeholders from across the Palo Alto area, and members of the Palo Alto
community. In order to ensure that the fire management recommendations addressed environmental and
cultural conditions that can affect resource and priority decisions, the update process included a series of specific objectives.
• Assess fire hazards within the project area. Develop fuel classification, weather condition
assumptions, and other fire hazard inputs used to model the fire hazards for the project area.
• Develop wildland fire management recommendations. Identify both developed and sensitive natural
resources at risk and develop treatment and best management practices to protect those resources.
Prepare appropriate California Environmental Quality Act (CEQA) document.
• Consider current refuge areas, ingress and egress routes and make recommendations for evacuation
from residential and public areas.
• Identify potential funding plans and external funding opportunities.
• Update the Foothills Fire Management Plan incorporating input from the community.
• Review and recommend appropriate revisions to existing City municipal ordinances pertaining to fire
prevention.
• Review and make appropriate recommendations to current levels of staffing, equipment and other response resources at Station 8 in Foothills Park.
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• Recommend revisions to the Pearson-Arastradero Preserve Trail Master Plan and Foothills Park Trail Maintenance Plan pertaining to firefighting access or vegetation management for fire hazard
reduction along trail corridors.
2.2 Planning History
The City of Palo Alto developed a Foothills Fire Management Plan in 1982. The 1982 Plan provides the
planning framework for fire control activities for the City and the Palo Alto Foothills Area. The goal of the
1982 Fire Management Plan is “to reduce government costs and citizen losses from wildland fire by increasing initial attack success and/or protecting assets at risk through focused pre-fire management
activities.”
In 1997, the City of Palo Alto staff developed a draft update to this plan. Although the draft update was not formally adopted, the 1997 Draft Palo Alto Foothills Fire Management Plan provides an updated framework and interim objectives for fire management within the Foothills Area.
The 1997 Draft Palo Alto Foothills Fire Management Plan identified four fire management objectives:
1. Identify fire pre-suppression, suppression and post-suppression activities to maintain or enhance the status quo, and prevent adverse impacts on people, structures and natural resources consistent with
Palo Alto Fire Department’s fire protection mission.
a. Prevent or reduce the threat of death or injury to foothills residents and visitors.
b. Prevent or reduce loss or damage to structures and natural resources.
2. Suppress fire in the Hazardous Fire Area before it gets out of control.
a. Perform effective initial attack, with Fire Station 8 staffed.
b. Develop pre-fire suppression plans (initial attack to 4-hour effort).
c. Incident Command System (ICS) training, focusing on multi-jurisdictional response and
enhancing Palo Alto Fire Department (PAFD) skills and abilities in specific ICS positions.
3. Review and update evacuation routes out of the Hazardous Fire Area.
4. When feasible and as part of a regional effort, establish optimal fire frequencies, use pre-suppression control measures (including controlled / prescribed burns) to restore optimal fire regimes and for
natural plant communities.
The 1997 draft plan identified several hazard mitigation categories to meet Palo Alto’s Fire Management goal and objectives.
• Fuel Management
o Roadside clearance – Page Mill Road, Arastradero Road, Los Trancos Road and Skyline Boulevard were identified as evacuation routes as well as firebreaks.
o Fuel Break/ Ignition Control system in Foothills Park and Pearson-Arastradero Preserve
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o Prescribed burning to reduce fuel load, re-establish a normal fire regime and educate and inform the public. High fuel loads, limited burn windows and requirements for pre-burn preparations have limited opportunities to date.
• Pre-fire Actions
o Foothills Park/ Pearson-Arastradero Preserve practices including visitor safety islands and
evacuation plans, fire-safe park maintenance practices, daily weather taking (establish daily
Burn Index), annual pre-fire season staff briefing, interagency training, use restrictions
during critical fire weather.
o Cooperative efforts with Midpeninsula Regional Open Space District (MROSD), the
Woodside Fire Protection District, and other partner agencies regarding construction of fuel
breaks, identification of evacuation routes and interagency training, public information about evacuation pre-planning.
o Private Dwellings and Open Land including fire codes for new development and public
education and code enforcement.
• Suppression and Post Suppression
o Suppression capability including Foothills Fire Facility (Station 8); Mutual Threat Zone/
mutual aid/ automatic aid contracts; interagency/ ICS training.
o Suppression Plan including maintenance of response cards, basing response on nationally-recognized fire danger rating indices, use any and all mutual aid resources to confine fires at
initial attack, and to follow fire management zone pre-planning documents.
o Post Suppression Plans.
o Cultural Resources (no significant cultural resources exist in the City Limits, but potential
always exists for discovery of new sites).
The 1997 draft plan strategically divided the Hazardous Fire Area into eight fire management zones (FMZs)
to merge individual property and resource concerns with fire control challenges (Figure 2). Each zone has a map showing boundaries, existing control lines and text description of activities to be considered by the
Incident Commander, safety precautions and other tactical or site-specific information.
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Figure 2: 1997 Fire Management Zones.
AP –Arastradero PreserveLTW –Los Trancos Woods
FP/VH –Foothills Park Vista Hill
FP/WVS –Foothills Park Wildhorse Valley SouthFP/WVN –Foothills Park Wildhorse Valley NorthCPM –Center Page Mill
UPM –Upper Page MillMBE –Monte Bellow East
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2.3 Scope of the Plan
The Fire Management Plan update process addresses a broad range of integrated activities and planning
documents to address and mitigate the impacts of fire hazards in the Palo Alto Foothills Area. The area of
interest includes the areas west of Foothills Expressway to the city limits of Palo Alto. The fire mitigation project areas include the boundaries of Foothills Park and Pearson-Arastradero Preserve within this area of
interest.
The Fire Management Plan Update addresses the following key items:
• Fire Hazard Assessment
• Regional Evacuation Routes
• Wildland Fire Management Recommendations and Mitigations
• Recommendations for the Foothills Park Trails Maintenance Plan and the Pearson-Arastradero Trails
Management Plan
• Review of Municipal Ordinances
• Staffing of Station 8
• Implementation Plan and Identification of Potential Funding
2.4 Planning Process
The process used in developing the Update to the Foothills Fire Management Plan involved several
departments of the City and many stakeholders. The consultants and City held three meetings with the
stakeholders between April and September 2008.
Invited Stakeholders included:
• Acterra
• Arrillaga Property: 500 Los Trancos Road
• CAL FIRE
• Friends of Foothills Park
• Los Altos Hills Fire District
• Los Altos Hills: ARES/RACES
• Los Trancos Water District
• Los Trancos Woods Neighborhood
• Menlo Park Fire District
• Midpeninsula Regional Open Space District
• PA Protect Our Open Space
• Palo Alto Hills Neighborhood Assoc
• Pony Tracks Ranch
• Portola Pasture Stables
• San Mateo County FireSafe Council
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• San Mateo County Sheriff
• Santa Clara County Fire Dept
• South Skyline Association
• Stanford Community Residential Leaseholders (SCRL)
• Stanford University
• Town of Los Altos Hills
• Vista Verde Community Association
• Woodside Fire Protection District
There were also three meetings with the community during the same time period. The meetings were held at the Interpretive Center at Foothills Park and at the Palo Alto Hills Golf and Country Club in Palo Alto.
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3 EXISTING CONDITIONS
3.1 Fire Hazard
There are many ways to assess fire hazard. Most utilize the three main factors of fuels, weather, and
topography, with possible inclusion of elevation or fire history. Fire behavior was chosen as the means to assess fire hazard since it integrates the effects of fuels, weather, and topography. Hazard assessments
developed by the State and the California Fire Alliance were evaluated for potential use. However, the
assessments were larger scale than appropriate for the purposes of this plan. The decision was made to use a more detailed, site-specific hazard assessment.
Fire behavior predictions identify locations where containment may be easiest, and where access may be
precluded during the time of a fire. In addition, fire behavior outputs can identify locations where structures
or natural resources may be unduly harmed by a wildfire, as well as locations where fire effects may be inconsequential to natural resources.
3.1.1 Vegetation and Fire Fuels
The Palo Alto Foothills contains a mix of potential wildland fire fuel regimes that, combined with the
topography and weather for the regime, pose a potential risk for wildland fire (Figure 3).
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Figure 3: Wildland Surface Fuels.
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3.1.2 Fire Behavior
3.1.2.1 Fire Behavior Modeling
FlamMap is particularly well suited for the Foothill Fire Management Area fire assessment. FlamMap
generates a spatial depiction of simulated fire behavior that may be used to assess relative hazards throughout the area.
FlamMap is a computerized fire behavior prediction model developed by the USDA Forest Service at the
Intermountain Forest Fire Research Laboratory.1 FlamMap was developed to predict fire behavior characteristics across a landscape. The first such landscape analysis of fire behavior characteristics was performed for the San Francisco Public Utilities Commission Bay Area watersheds, then applied across the
East Bay Hills after the Oakland Hills Fire. FlamMap is currently in the public domain.
The heat transfer formulas in FlamMap are based on the software program, BEHAVE, which has been used in wildfire prediction since the 1970's. FlamMap uses the same heat transfer algorithms as BEHAVE along with
numerous other algorithms to predict crown fire potential, ember distribution, effects of terrain on wind,
direction and slope, and more.
FlamMap allows prediction of fire behavior on a spatial basis, by modeling the locations of flame length, heat release, and rate of spread along with type of fire (crown fire, surface fire, or a fire that torches individual
trees) throughout an entire area. FlamMap simulations assume the entire area is aflame under the same
conditions at the same time to determine spatial differences in fire behavior.
3.1.2.2 Spatial Input Files
The spatial data inputs to FlamMap characterize the terrain, weather, and fuels on the site with eleven
different data layers. The spatial input data files are described in Figure 4.
Figure 4: Spatial Data Required for Fire Behavior Modeling.
Level Purpose Source
Elevation (feet
above sea level) This is necessary for adiabatic adjustment of temperature
and humidity between elevations and for conversion of fire spread between horizontal and slope distances.
USGS digital elevation models
Slope (Percent of
inclination from the horizontal)
Slope is used to compute steepness effects on fire spread
and solar irradiance.
USGS digital elevation models
Aspect (Azimuth
values degree
clockwise from north)
Aspect is used to compute effects on fire spread and solar
irradiance.
USGS digital elevation models
Fuel Model Fuel models, organized and described according to the FRAP
1 (FlamMap is available from Systems for Environmental Management, PO Box 8868, Missoula, MT,
59807, or from www.fire.org/tools.)
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Level Purpose Source
Fire Behavior Prediction System in terms of fuel volume, structure, and chemistry. The fuel models were mapped
by CalFire in the Forest Resource Assessment Program (FRAP).
Canopy Cover Canopy cover is necessary to compute shading and wind
reduction factors. Canopy cover was mapped for the LandFire Program.
LandFire Program
Tree Height Tree height is used to compute spotting distance and
crown fire characteristics. Decision rules regarding tree heights were applied to FRAP surface fuels.
Crosswalk from FRAP surface
fuels
Crown Base Height or Height to Live Canopy
Crown base height is an important parameter for determining the transition from surface fire to crown fire.
This value incorporates the effects of ladder fuels in increasing vertical continuity and assisting transition to
crown fire. Crown base height was mapped for the LandFire Program.
LandFire Program
Weather and Wind Weather is important to determine environmental
conditions during the simulation. The weather data theme describes the maximum and minimum
temperatures and relative humidity, and the time in which
the maximum and minimum temperature occurs in order to dry and moisten fuels accordingly. Weather data that
CalFire based fire-related policy decisions (defined as “average-bad” conditions) was used for this project.
CalFire-defined weather for
average bad fire danger
Figure 4: Spatial Data Required for Fire Behavior Modeling.
3.1.2.3 User-Defined Inputs
The model allows the user to customize fuel models or fuel moisture with special files2.
Custom Fuel Model Files - custom fuels can be used to more accurately describe the types of fuel models
found on the site. Custom fuel models use a standard fuel model as a base. In cases where especially flammable vegetation are present (eucalyptus and pines), the heat content of the dead and live fuels could be
raised. In cases where the foliage are expected to be moister, the initial fuel moisture of the living material
can be raised. Fuel volumes and heights in grazed grasslands can also be reflected in a cus t o m m o d e l . F o r the Palo Alto hazards assessment no custom fuel models were used.
Fuel Moisture Files - defines the initial fuel moisture for each size class of fuels, for each fuel model. The
moisture content of live woody fuels and live herbaceous fuels are similarly defined for each fuel model. This
file specifies the moisture in the fuels of various sizes, and specifies how much moisture is in leaves. Based on this information, the weather files either dry out or add moisture to fuels depending on ambient conditions.
The fuel moisture file used for the Palo Alto hazard assessment portrays the “average worst” fire danger as
defined by CalFire. The “average worst” generally applies to the conditions that exist fewer than 10 percent of the time. It is also known as the 90th percentile weather conditions.
2 User-defined inputs could capture the effects of Sudden Oak Death through development of a custom
fuel model and associated reduced fuel moisture.
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3.1.2.4 FlamMap Results
Fire behavior was analyzed for the entirety of the Foothills area, including adjacent neighborhoods, property owned by Midpeninsula Regional Open Space District and Stanford University. Three factors
are especially pertinent for prioritizing locations of high fire hazard: crown fire activity, flame length and
rate of spread.
Crown Fire Potential - Crowning activity indicates locations where fire is expected to travel through and likely consume the crowns. When a fire burns through tree crowns, countless embers are produced and are
distributed, sometimes at long distances. These embers can start new fires, which can each grow and
confound the finest fire suppression forces. For management purposes, prediction of torching or crown fire is highly correlated with fire severity. Crown fire activity is of concern wherever it occurs because of its impacts and the containment challenges.
There is very little active crown fire predicted within the Foothills area, however, the potential for trees to
torch is high throughout the treed portion of the Foothills area. Torching is caused by low-hanging limbs, or ladder fuels (Figure 5). The Crown Fire Potential across the Palo Alto area of interest is depicted in Figure 6.
Figure 5: Comparison of Torching and Active Crown Fire.
Flame Length - Flame length closely corresponds to fire intensity, which can predict fire severity. This
factor most influences probability of house damage and ease of fire control. A flame length of eight feet is usually looked at as a cut-off point for decisions whether to attack the fire directly, or instead attempt control
through indirect methods.
Fire intensity was determined to be the most important factor in many studies of structural damage from fire. Flame lengths are often used as a proxy for fire intensity because they are highly correlated to fire intensity.
Long flame lengths may justify treatment where they occur near sensitive values-at-risk.
Flame lengths follow fuel types, with long flame lengths in chaparral and untreated grass, and short flame
lengths in woodlands and mowed grass. The largest areas of long flames are located in Foothill Park and Monte Bello Open Space Preserve. Predicted Flame Length is depicted in Figure 7.
Rate of Spread - The rate of spread is most closely associated with the ability to contain a fire. Rates of
spread analyses point to the needs for increased access, detection, reporting, and fuel management to slow fire
spread in strategic locations.
Low fire spread rates were predicted in woodlands and forests, and fast spread rates in untreated grass and
chaparral. Predicted Rate of Spread is depicted in Figure 8.
Torching Active
Crown Fire
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Figure 6: Crown Fire and Torching Potential.
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Figure 7: Predicted Flame Length.
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Figure 8: Predicted Rate of Spread.
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3.2 Fire Suppression Capabilities
The Department's response area in the WUI Fire Area covers nearly 10 square miles, from Skyline Boulevard
in the Palo Alto foothills to Foothill Blvd and from Page Mill Road to Los Trancos Road. Approximately
200 residences and large business complexes (some of them exceeding a million square feet in area) are located in Palo Alto’s Wildland Urban Interface Fire Area. The City of Palo Alto Emergency Operations Plan
(June 2007) notes that 11 health care facilities, 10 schools and 25 government-owned buildings are located in
the wildland urban interface threat areas, along with 19 miles of roadway that are subject to high, very high or
extreme wild fire threat.
The Fire Department has 122 personnel organized in four areas:
• Emergency Response (Operations)
• Environmental & Safety Management (Fire Prevention Bureau)
• Training & Personnel Management (Support)
• Office of Emergency Services
The Fire Department staffs seven full time stations located strategically throughout the City. To provide
coverage in the sparsely developed hillside areas, an additional fire station in the foothills is operated during summer months when fire danger is high.
The Fire Department facilities are located as follows:
Fire Administration 250 Hamilton Avenue, City Hall
Fire Station 1 301 Alma Street
Fire Station 2 2675 Hanover
Fire Station 3
799 Embarcadero Road
Fire Station 4
3600 Middlefield Road
Fire Station 5
600 Arastradero Road
Fire Station 6
711 Serra Street, Stanford
Fire Station 7
2575 Sand Hill Road, Menlo Park
Fire Station 8
Foothills Park
Rangers from the Open Space and Parks Division perform a vital service aiding fire suppression, providing
detection, notification and initial size-up of fires, along with evacuation or reconnaissance. The Rangers offer detailed local knowledge, and support the Station 8 firefighters. Currently ten staff are fully trained and equipped for first response. There are four trucks with 150-200 gallons of water.
The City of Palo Alto has secured many agreements that augment fire suppression capabilities. They
participate in the California Master Mutual Aid Agreement and supporting separate agreements. During a
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proclaimed emergency, inter-jurisdictional mutual aid will be coordinated at the County Operational Area (Santa Clara County OES, or EOC, if activated), or Mutual Aid Regional level whenever the available resources are:
• Subject to state or federal control.
• Subject to military control.
• Located outside the requesting jurisdiction.
• Allocated on a priority basis.
The current Insurance Service Organization rating for the City of Palo Alto is ISO Class 2.
3.3 Access
Regional access to the Foothills Area is provided by Highway 280, Foothill Expressway and Skyline
Boulevard. Page Mill Road serves as a major north-south connector from Highway 280 to Skyline
Boulevard. Los Trancos Road provides access along the western boundary of the Palo Alto Foothills Area from Alpine Road south to Los Trancos Woods. Page Mill Road and Los Trancos Road have several long
sections that are steep, windy and narrow.
Circulation is limited within the Foothills Area. Arastradero Road links the western and eastern portions. Alpine Road and Los Trancos Road provide access to portions of the western part of the City. Moody Road
and Altamont Road are other important circulation routes in Los Altos Hills.
3.4 Sensitive Resources
The Palo Alto Foothills Area includes a mix of social and environmental attributes that may be adversely
affected by wildland fire or proposed fuel treatments and strategies. Areas that hold cultural or environmental
significance enhance the quality of life in the City of Palo Alto and provide habitat for a variety of plant and wildlife species. These sensitive resources are valuable to the Palo Alto community and to the ecosystem;
they should be protected and preserved. Actions are proposed that will reduce the risk of fire spreading to
sensitive resources and otherwise minimize the damage to those resources.
Social and cultural factors that may exist in the area affect fire management planning and include specific land uses such as agriculture and rangeland, the presence of public service utilities and structures, and the
presence of historical or cultural artifacts. Environmental concerns include vegetation communities, wildlife
habitat, soil and erosion conditions, and water and air quality. Figures 9 and 10 provide an overview of potential sensitive resource locations throughout the two parks.
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 29
Figure 9: Locations of Cultural and Environmental Sensitive Resources in Pearson-Arastradero Preserve.
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 30
Figure 10: Locations of Cultural and Environmental Sensitive Resources in Foothills Park.
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 31
3.4.1 Social and Cultural Features
Social and cultural features are areas and activities that have a special community attribute or contribution
ranging from the value of personal property to the functioning of public service and public safety operations. Foothills Park and Pearson-Arastradero Preserve are both open space areas dedicated for park, recreation and
conservation purposes. They are generally undeveloped except for park amenities, utilities, public service and
safety infrastructure, and roads and trails. The projects in this plan pertain directly to the lands within
Foothills Park and Pearson-Arastradero Preserve, and along the evacuation routes within the City limits of Palo Alto. The lands adjacent to the parks include residential and private property as well as public and
private open space, and are affected by fire management through code modification, fire department staffing,
and other non-project measures that reduce the risk of fire spreading to these resources along with minimizing potential damages. The residential and private property adjacent to the parks include:
• Open space owned and managed by the Midpeninsula Regional Open Space District and Stanford
University
• Private residences in the Town of Los Altos Hills, Town of Portola Valley, City of Palo Alto, Santa
Clara County, and San Mateo County
• Neighborhoods/associations such as Altamont, Los Trancos Woods, Vista Verde, Blue Oaks, Portola
Valley Ranch, Palo Alto Hills, Montebello, South Skyline, and others
• Privately-held recreation facilities, such as equestrian centers and the Palo Alto Hills Golf and Country Club
• The site of what was a private research facility (the American Institute of Research)
Both Foothills Park and Pearson-Arastradero Preserve contain utility lines and access roads that are used and maintained by the City of Palo Alto. The Pearson-Arastradero Preserve contains overhead electrical utility
lines that enter the Preserve from Arastradero Road and extend along Arastradero Creek. South of Foothills
Park, transmission lines run east-to-west across the southern edge of the park near Page Mill Road and Montebello. The Arastradero and Foothills parks contain several reservoirs, booster stations, and water and sewage lines. The external, aboveground portions of this infrastructure represent potential features that must
be taken into consideration either as values at risk to wildland fire or included in fire mitigation treatment
planning and execution.
The primary structures within the two parks include the Foothills Park interpretive center, Pearson-
Arastradero Gateway interpretive center, Fire Station 8, a maintenance complex, and three public restrooms.
No significant cultural or historical sites have been found within the park areas. However, the Foothills area is similar to other areas in the Santa Cruz Mountains that have provided hunting, fishing, and encampments for Native American tribes. A potential exists for discovery of cultural or historic sites.
3.4.2 Environmental Features
Environmentally sensitive areas are those that have specific characteristics which the community, State, or
nation has determined to be worthy of protection or preservation. These can include the maintenance of a
diverse plant and wildlife ecosystem or the protection of endangered or threatened species. The Palo Alto Foothills hold a specific environmental value within the City of Palo Alto as a conservation area as well as a
mixed -use area supporting private and public activities.
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 32
Foothills Park and Pearson-Arastradero Preserve consist of a mix of grassland, mixed evergreen, oak woodland, riparian areas (creek, lake), and chaparral. The two parks are located in the watershed of Los Trancos Creek and Arastradero Creek. Foothills Park contains the headwaters of Arastradero Creek and is
downstream of Los Trancos Creek and contains Boronda Lake. The Arastradero Creek, an unnamed tributary
to Arastradero Creek, and an unnamed tributary to Los Trancos Creek run through the Arastradero Preserve. The Pearson-Arastradero Preserve also contains a small lake, called Arastradero Lake, and John Sobey Pond.
The Palo Alto Foothills contain several environmental areas that deserve specific consideration in the Fire
Management Plan. These areas represent the combined contributions of unique wildland habitat capable of
supporting a mix of wildlife, a diverse plant and wildlife population containing several protected and monitored species, and a mix of ecosystems ranging from riparian areas to serpentine soils.
3.4.2.1 Species and Wildlife
The variety of environmental conditions in Foothills Park and Pearson-Arastradero Preserve provide habitat
for a broad range of wildlife and plants – including some designated as protected or sensitive either by the State of California or the Federal government (Figure 11).
The parks provide known habitat for two protected species and potential habitat for several others –
particularly in the riparian zones and areas near Boronda Lake and Arastradero Lake. The California Red-Legged Frog and Steelhead Trout are known to inhabit Los Trancos Creek. In addition, the riparian areas, grasslands, and oak woodlands above Los Trancos as well as Boronda Lake may provide additional foraging
and breeding habitat for the California Red-Legged Frog.
Several species of sensitive plants and animals have been locally identified within the parks. In addition, the parks provide potential habitat for a variety of bird and plant species of concern, ranging from plants such as
the Santa Clara Red Ribbon to mammals such as the San Francisco Dusky-footed Woodrat. The potential
habitats for these species include the riparian and wetland areas along Los Trancos, Boronda Lake, Arastradero Lake, and John Sobey Pond; the serpentine soil areas identified in Pearson-Arastradero Preserve; and the Oak Woodland and Chaparral zones. In addition to these sensitive species, there are also plant species
of local concern, such as Phacelia and bush poppies.
The following is a table highlighting sensitive species that may be present in the parks. It is possible that additional sensitive species or habitat areas may be discovered in the future.
Figure 11: Sensitive Species Known or Potentially Occurring in Foothills Park or Pearson-Arastradero Preserve.
Federal
Status
California
Status Asset Name Geographic Extent Mapping Location
Endangered Endangered San Francisco garter snake (Thamnophis
sirtalis tetrataenia)
POTENTIAL HABITAT - potential habitat in Boronda Lake;
suitable habitat in Arastradero Lake.
Boronda Lake, Arastradero Lake
N/A Protected Ringtail (Bassariscus astutus) POTENTIAL HABITAT - Forage habitat in riparian zone; possible nesting in hollow trees in riparian zones. Los Trancos Creek
provides most likely habitat.
Los Trancos Creek
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 33
Federal Status California Status Asset Name Geographic Extent Mapping Location
N/A Endangered Point Reye’s meadowfoam
(Limnanthes douglasii sulphurea)
POTENTIAL HABITAT - freshwater marsh occurs in
Arastradero Lake; some wet areas in grassland near Arastradero
Creek may provide habitat.
Arastradero Lake, Arastradero Creek and tributary grasslands
Endangered CNPS: Rare, threatened, or endangered in
CA
Contra Costa goldfields (Lasthenia conjugens) NOT LIKELY - Could possibly occur in wet areas in grassland, although the likelihood is very
low.
Endangered Endangered San Mateo thorn-mint (Acanthomintha duttonii) UNKNOWN - Info pulled from CNDDB Palo Alto topo map - not
mapped.
Species of
concern
DFG: Species
of special concern
Western pond turtle
( A c t i n e m y s m a rmorata)
POTENTIAL HABITAT -
Potential habitat in Boronda Lake, Los Trancos Creek, and
Arastradero Creek; possible sighting in Arastradero Lake;
habitat onsite includes Arastradero Creek, John Sobey Pond, Arastradero Lake, and the
unnamed tributary to Los Trancos Creek.
Boronda Lake, Los Trancos
Creek, Arastradero Creek, John Sobey Pond, Arastradero Lake,
Tributary for Los Trancos Creek
Threatened DFG: Species of special concern
California red-legged frog (Rana aurora draytonii)
KNOWN and POTENTIAL HABITAT - potential breeding habitat at Boronda Lake, Los Trancos Creek and tributaries,
John Sobey pond, and Arastradero Lake; foraging habitat in riparian
zones, grassland, and oak woodland above Los Trancos Creek and tributaries; May occur
on Los Trancos Trail.
(1) Boronda Lake, Los Trancos Creek and tributaries, John Sobey Pond, Arastradero Lake (2) Riparian Zones
(3) Grasslands, Oak Woodlands in vicinity of Los Trancos Creek
(4) Los Trancos Trail
Threatened DFG: Species of special
concern
California tiger salamander (Ambystoma
californiense)
POTENTIAL HABITAT - breeding habitat may occur in the
“bowl” near the top of the Pearson-Arastradero Preserve, which is in proximity to the
unnamed tributary to Los Trancos Creek
Unnamed tributary to Los Trancos Creek
Threatened DFG: Species
of special concern
North Central Coast
steelhead/sculpin stream
KNOWN HABITAT - Los
Trancos is a known steelhead stream.
Los Trancos Creek
Threatened DFG: Species of special
concern
Steelhead Trout (Oncorhynchus mykiss
irideus)
KNOWN HABITAT - Los Trancos is a known steelhead
stream.
Los Trancos Creek
N/A CNPS: Rare, threatened, or endangered in
CA
Ben Lomond buckwheat (Eriogonum nudum var. decurrens)
POTENTIAL HABITAT - Habitat present in chaparral and woodland.
Chaparral, woodland
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 34
Federal Status California Status Asset Name Geographic Extent Mapping Location
N/A CNPS: Rare, threatened, or
endangered in CA
Big-scale balsamroot (Balsamorhiza
macrolepis)
POTENTIAL HABITAT - Habitat present in grassland and
oak woodland.
Grassland, Oak Woodland
N/A CNPS: Rare,
threatened, or endangered in CA
Delta tule pea (Lathyrus
jepsonii)
POTENTIAL HABITAT - fresh
water marsh occurs in Arastradero Lake, and may occur in Arastradero Creek and the
tributary to Arastradero Creek.
Arastradero Lake, Arastradero
Creek and tributary to Arastradero Creek
N/A CNPS: Rare, threatened, or
endangered in CA
Legenere (Legenere limosa) POTENTIAL HABITAT - Potential habitat along drainages,
Boronda Lake.
Boronda Lake
N/A CNPS: Rare, threatened, or
endangered in CA
Robust monardella or Round-headed coyote
m i n t (Monardella villosa ssp.
globosa)
PRESENT/POTENTIAL HABITAT – Locally identified
habitat present in woodland and chaparral. Every trail has either
woodland or chaparral, or both habitats.
Woodland and chaparral
N/A CNPS: Plant of limited
distribution
Santa Clara red ribbons (Clarkia concinna
automixa)
PRESENT (Foothills)/POTENTIAL
HABITAT - Habitat present in oak woodland areas along trails
Oak Woodland
N/A CNPS: Rare, threatened, or
endangered in CA
Santa Cruz manzanita (Arctostaphylos
andersonii)
POSSIBLE HABITAT/NOT LIKELY - Low possibility in oak
woodland and chaparral. Every trail has either woodland or
chaparral, or both habitats.
Oak woodland and chaparral
N/A CNPS: Rare, threatened, or endangered in
CA
Serpentine-based plants KNOWN - two areas of serpentine soil have been identified in Arastradero; one is in
grassland and the other is in chaparral. No occurrences in
Foothills although some soil/landcover data have noted potential areas.
Areas of Serpentine Soil in Arastradero (Grassland, chaparral). Some potential areas
in Foothills
N/A CNPS: Rare,
threatened, or endangered in
CA
Dudley's lousewort
(Pedicularis dudleyi)
NOT LIKELY - Coniferous
forest, maritime chaparral. These habitats are not present in
Foothills Park.
Endangered CNPS: Rare,
threatened, or endangered in
CA
Showy Indian clover
(Trifolium amoenum)
NOT LIKELY
(Foothills)/POSSIBLE (Arastradero) - Info pulled from
CNDDB Palo Alto topo map, seeps in grassland.
Threatened N/A Bay checkerspot butterfly (Euphydryas editha
bayensis)
NOT LIKELY - serpentine grassland areas either too small or
not present
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 35
Federal Status California Status Asset Name Geographic Extent Mapping Location
N/A CNPS: Plant of limited
distribution
Gairdner’s yampah (Perideridia gairdneri) KNOWN - in grassland, riparian areas of Arastradero. Riparian, Grasslands
N/A CNPS: Plant of limited
distribution
Mexican mosquito fern (Azolla mexicana) POTENTIAL HABITAT - Potential habitat in Boronda Lake;
Arastradero Creek from John Sobey Pond to Arastradero Lake
Boronda Lake; Arastradero Creek from John Sobey Pond to
Arastradero Lake
N/A CNPS: Rare, threatened, or
endangered in CA
White-flowered rein orchid (Piperia candida) POSSIBLE HABITAT - Potential habitat along portions of Chamise,
Coyote, Fern Loop, Los Trancos, Panorama, Toyon and Woodrat
Trails.
Oak Woodland
N/A DFG: Species
of special concern
Long-eared owl (Asio
otus)
POTENTIAL HABITAT - May
use oak woodland and riparian corridors in Foothills Park.
Includes Chamise, Costanoan, Coyote, Fern Loop, Los Trancos,
Panorama, Sunrise, Trappers, and Woodrat Trails.
Oak Woodland, Riparian Zones
N/A Species of special
concern
Big brown bat (Eptesicus fuscus) POTENTIAL HABITAT - Potential forage habitat. Oak Woodland, Riparian Zones
N/A Species of special concern
California myotis (Myotis californicus) POTENTIAL HABITAT - Potential forage habitat. Oak Woodland, Riparian Zones
N/A BLM:
Sensitive
Long-eared myotis
(Myotis evotis)
POTENTIAL HABITAT -
Potential forage habitat.
Oak Woodland, Riparian Zones
N/A IUCN: Species of concern
Long-legged myotis (Myotis volans) POTENTIAL HABITAT - Potential forage habitat. Oak Woodland, Riparian Zones
N/A Species of
special concern
Mexican free-tailed bat
(Tadarida brasiliensis)
POTENTIAL HABITAT -
Potential forage habitat.
Oak Woodland, Riparian Zones
N/A IUCN: Species of
concern
Silver haired bat (Lasionycteris
noctavigans)
POTENTIAL HABITAT - Potential forage habitat. Oak Woodland, Riparian Zones
N/A DFG: Species of special concern;
BLM: Sensitive;
IUCN: Species of
concern; USFS: Sensitive
Townsend’s western big-eared bat (Corynorhinus townsendii townsendii)
POTENTIAL HABITAT - Potential forage habitat. Oak Woodland, Riparian Zones
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 36
Federal Status California Status Asset Name Geographic Extent Mapping Location
N/A IUCN: Species of
concern; BLM:
Sensitive
Yuma myotis (Myotis yumanensis) POTENTIAL HABITAT - Potential forage habitat. Oak Woodland, Riparian Zones
N/A DFG: Species of special concern;
BLM: Sensitive;
IUCN: Species of
concern; USFS: Sensitive
Pallid bat (Antrozous pallidus) POTENTIAL HABITAT - throughout Pearson-Arastradero Preserve.
Oak Woodland, Riparian Zones
Species of
concern
DFG: Species
of special concern; BLM: Sensitive; IUCN:
Species of concern;
USFS: Sensitive
Foothill yellow-legged
frog (Rana boylei)
POTENTIAL HABITAT -
Potential habitat in Los Trancos Creek and tributaries. May occur on Los Trancos Trail; suitable habitat in Arastradero Creek and the unnamed tributary to Los
Trancos Creek.
Los Trancos Creek, Arastradero
Creek, Tributary
None Locally unusual BlueGrey Gnatcatcher (Polioptila caerulea)
PRESENT – Locally identified in North Coastal Scrub, coyote
brush.
Arastradero Creek and Juan Bautista de Anza Trail
N/A CNPS: Rare, threatened, or endangered in
CA
Franciscan onion (Allium peninsulare var. franciscanum)
POTENTIAL HABITAT – Habitat present in oak and mixed evergreen woodland, and
grasslands.
Oak Woodland, Grasslands, Evergreen Woodlands
Species of concern DFG: Species of special
concern: IUCN: Species of
concern
Saltmarsh common yellowthroat (Geothlypis
trichas sinuosa)
POTENTIAL HABITAT – May use Boronda Lake. Riparian
habitat, John Sobey pond and Arastradero Lake.
Riparian Zones including Boronda Lake, John Sobey
pond, Arastradero Lake
N/A CNPS: Rare, threatened, or
endangered in CA
San Francisco collinsia (Collinsia multicolor) POTENTIAL HABITAT – Habitat present in oak woodland. Oak Woodland
N/A DFG: Species of special
concern; IUCN: Species of concern
San Francisco dusky-footed woodrat (Neotoma
fuscipes annectens)
PRESENT/POTENTIAL HABITAT – Known to occur
along Woodrat Trail. Nesting habitat in riparian vegetation and oak woodland, forage in all habitats on site.
Woodrat Trail, restoration site near Arastradero Road, and
Arastradero Creek Trail
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 37
Federal Status California Status Asset Name Geographic Extent Mapping Location
N/A CNPS: Rare, threatened, or
endangered in CA
Western leatherwood (Dirca occidentalis) POTENTIAL HABITAT (Arastradero)/KNOWN
(Foothills) – Oak woodland and riparian; Foothill woodland,
mixed evergreen forest and riparian. Occurs on site along the
Los Trancos and Steep Hollow Trails.
Los Trancos and Steep Hollow Trails in Oak Woodlands and
Riparian areas
N/A CNPS: Plant of limited
distribution
Forget-m e -not popcorn flower (Plagiobothrys
myosotoides)
POTENTIAL HABITAT (Foothills)/NOT LIKELY
(Arastradero) – Habitat present in chaparral.
Chaparral in Foothills
N/A CNPS: Rare, threatened, or
endangered in CA
Slender-leaved pondweed (Potamogeton filiformis) NOT LIKELY – Possibly in Arastradero Creek/Boronda Lake
and unnamed creeks in the Preserve, presumed extinct in
Santa Clara County; not known from San Mateo County.
N/A CNPS: Rare, threatened, or
endangered in CA
Congdon’s tarplant (Centromadia/Hemizonia
parryi ssp. Congdonii)
NOT LIKELY (Foothills)/POSSIBLE (Pearson-
Arastradero) – Info pulled from CNDDB Palo Alto topo map,
seeps in grassland.
N/A CNPS: Rare, threatened, or endangered in
CA
Fragrant fritillary (Fritillaria liliacea) NOT LIKELY (Foothills)/POSSIBLE (Pearson-Arastradero) – Info pulled from
CNDDB Palo Alto topo map, seeps in grassland.
Figure 11: Sensitive Species Known or Potentially Occurring in Foothills Park or Pearson-Arastradero Preserve.
3.4.2.2 Soils and Geology
Soil erosion occurs when soil materials are worn away and transported by wind or water. The soils that comprise Foothills Park and Pearson-Arastradero Preserve include some soil and slope combinations that
represent potential erosion hazards that could be accentuated by wildland fire events that remove significant
portions of vegetation or some forms of fuel treatments that disturb ground cover. Figure 12 lists the potential
erosion hazards posed by soil mapping units that comprise portions of the parks. Due to the presence of several highly and moderately erodible soil types, the areas that represent significant hazards from either fire
or treatment are those with slopes in excess of 15 %.
Soil Mapping Unit Soil Name Location Erosion Hazard
Los Gatos-Maymen
Complex (50-75% slope)
Los Gatos Gravelly Loam Foothills Park & Pearson-Arastradero Preserve Very High
Maymen Rocky Fine Sandy Loam Foothills Park Very High
Los Gatos Clay Loam
(15-30% slope)
Los Gatos Clay Loam Foothills Park Moderate
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 38
Soil Mapping Unit Soil Name Location Erosion Hazard
Los Osos Clay Loam (15-30% slope) Los Osos Clay Loam Pearson-Arastradero Preserve Moderate
Azule Clay Loam (15-30%) Azule Loam Pearson-Arastradero Preserve Slight to Moderate
Cropley Clay (2-9%
slope)
Cropley Clay Foothills Park Slight
Pacheco Clay Loam Pacheco Clay Loam Pearson-Arastradero Preserve Slight
Pleasanton Loam Pleasanton Loam Pearson-Arastradero Preserve Slight
Figure 12: Soil Types in Foothills Park and Pearson-Arastradero Preserve.
Derived from STATSGO2 data and research from City of Palo Alto Trail Management Plans.
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 39
4 FUEL MANAGEMENT IN CITY PARKS
Not every area identified as a potential fire hazard can be modified to produce low-intensity fires. Not only
would this be too costly, but environmental impacts would also be unacceptable. Fires that burn in un-treated
areas will not benefit from treatment elsewhere. The exception is that the fire may be contained in the treated
area, thereby never reaching the untreated area.
4.1 Identifying Potential Treatment Areas
Selection of pre-fire fuel treatment areas is based on the probability of the event and the potential damage of that event. Factors taken into consideration are:
• Need for enhanced access and egress: Actions to promote life safety and efficient emergency
response is of utmost importance. Roadside treatments that aid safer access and evacuation have a high likelihood and magnitude of benefit.
• Ignition locations: Treatments are located either where ignitions are likely to occur or could spread
into (e.g. a grassy spot near a road, or near a barbeque). Even where an area would burn with great ferocity, if there is only a remote chance of ignition, it has a lower treatment priority.
• Adjacency to improvements or other sensitive values at risk from wildfire: The closer the fuel
source is to a structure, heavily used area, or environmentally sensitive area, the higher the treatment priority. Therefore, an area in the interior of a Park/Preserve, well removed from other
vulnerabilities, should not be treated with the same priority as a hazardous situation near valuable
and/or vulnerable resources.
• Propensity of the treatment to aid containment: Treatments that facilitate access or create
locations where containment is likely to be successful have greater benefit because they improve fire
suppression success. Also, a fire that is easy to contain will be more likely to have fewer environmental impacts from the suppression action itself.
In the end, the most intense fire, and possibly the largest potential fire size, may not be highest on the
treatment priority list. This may be because the likelihood of the event coupled with the potential damage
from the fire would not yield the highest risk.
4.2 Establishing Project Objectives
Projects are justified by various objectives, spanning the need to keep fires from crossing boundaries, minimizing damage to developed areas, and minimizing damage to natural resources. Others comply with
regulations, which themselves are intended to increase access, facilitate fire suppression and minimize
resource damage.
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 40
The following table (Figure 13) is an outline of project goals and actions:
Project Goal Actions
Maintain ability for safe
access and egress and refuge during
suppression activities
• Roadside and driveway fuel modification to reduce fire intensity to allow for firefighting vehicles access and ensure safe passage for staff and visitors to pre-
determined safety zones.
• Improve access to potential wildfire locations to increase effectiveness of firefighting
resources (road realignments, access upgrades)
• Identify areas for potential use for firefighter safety and refuge during a fire (safety
zones)
Minimizing damage to developed areas • Reduce potential for ember production,
• Manage fuels along borders with structures, anywhere around structures (within 100 feet)
• Retrofit structures to make them more ignition-resistant
• Enhance firefighting effectiveness
• Reduce fuels around other facilities at risk (e.g. communications equipment, high use recreation areas)
Reduce damage to
structures and developed areas from wildfire near
structures
• Manage fuels per Defensible Space Guidelines to reduce flame length to 2 feet within 30 feet of structures
Reduce potential for
ignitions • Roadside fuel treatments
• Reduce fuels around barbeque sites and selected electrical transmission lines
• Ensure mechanical equipment has features to minimize ignitions
• Conduct fuel management in a manner that prevents ignitions
Facilitate containment
and control of a fire • Strategically compartmentalize fuels in order to facilitate containment and control
• Modify fuels to reduce fire intensity and allow firefighters better access to the fire,
slow spread of fire and make firefighting actions more effective,
• Modify fuels to allow for backfires
Reduce the chance of
damage to life and property by keeping fire
from crossing boundaries – Participate in
cooperative projects with adjacent landowners
• Fuel management to compartmentalize the landscape
• Fuel management along the borders of the Park/Preserve
• Modification of the volume or structure of the fuels to reduce chance of ember
production
• Modification of the volume or structure of the fuels to enhance firefighting effectiveness
Minimize damage to natural resources • Conduct pre-treatment surveys for sensitive species
• Follow best management practices during fuel management
• Fuel management around fire-sensitive areas to reduce fire intensity
• Use of modified fire suppression in sensitive areas
Fuel modification for ecosystem health • Reduce invasive species
• Perform selected prescribed burns to promote fire-adapted native species
Figure 13: Project Goals and Actions.
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 41
4.3 Current Fuel Management Program
Fuel Management is not new in the two parks. The two parks have a long history of managing vegetation to
both promote fire safety and to enhance natural resources (Figures 14 and 15). In some cases, projects attain
both goals. Previous projects in Foothills Park encompass discing along park boundaries, grazing with goats in Las Trampas Valley, maintenance of a mowed fuel break along various locations, including a broad fuel
break sometimes 200-ft wide along Trappers Ridge, and more narrow fuel breaks along the Madrone Fire
Road, Shotgun Fire Road, Pony Tracks Fire Road, and around Station 8. Fuel management in Pearson-
Arastradero includes discing along park boundaries, mowing 14 different broad areas within the park, and maintenance of vegetation along park roads. Figures 16 and 17 highlight specific mowing and grazing areas
for both parks from 2001 to 2008.
Grading (of the fire roads) has been a component of the contract between Van der Steen General Engineering
and Palo Alto for annual firebreak maintenance.
Grading has been performed as part of this contract only in the last three years; low annual rainfall and
erosion has not warranted grading. To minimize grading work, city employees from all departments are
strictly prohibited from driving the bare soil roadways that do not have asphalt or compacted rock. Grading,
as a component of the contract, is specified as only when necessary.
Discing has been performed by City staff for the last 7+ years. After trials with several methods, the City found that a two discing cycles work best. The first cycle is performed when the threat of spring rains has
diminished, drainages or low areas are dry, and annual grasses are still green. The depth of discing is less
than 6-inches, and causes a disruption of the growth of the annual grasses (less biomass). The second cycle of discing is after the annual grasses have cured/dried but there is still some soil moisture. Discing is full depth
or up to 10-inches. Completely dry soil makes traction nearly non-existent, which is a safety hazard for the
equipment operator, and produces copious amounts of dust to the surrounding area during both discing and
grading operations.
Mowing is routinely conducted during the early summer by City staff for resource enhancement. Figure 16 indicates the areas within Pearson -Arastradero Preserve that are mowed at least annually. Approximately 200
acres are routinely mowed. Outside of the areas mowed for resource enhancement, large areas are mowed
annually in Foothills Park as part of a fuel break. A fuel break is mowed on Trappers Trail, varying from 100-ft to 300-ft in width. Another area routinely mowed is along Pony Tracks Fire Road from the
intersection of Los Trancos Trail to Page Mill Road. Most areas are less than 100-ft but the area between
Pony Tracks and Los Trancos Trail can reach 300-ft in width.
Grazing with sheep and goats is a relatively new component of the fuel management program within the City of Palo Alto Parks. Approximately 5 acres were grazed in 2007 in Las Trampas Valley in Foothill Park, the picnic areas near the road.
Defensible Space is maintained near existing structures in Foothills Park and Pearson-Arastradero Preserve.
This employs the use of hand labor to limb trees and shrubs, cut grass, landscape with fire-resistant plants,
and irrigate selected plants.
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Draft (15 January 2009) 42
Figure 14: Pearson-Arastradero Preserve Current Fuel Management Areas.
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Draft (15 January 2009) 43
Figure 15: Foothills Park Current Fuel Management Areas.
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Draft (15 January 2009) 44
Figure 16: Recent Treatments in Pearson-Arastradero Preserve.
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Figure 17: Recent Treatments in Foothills Park.
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4.4 Project Description
4.4.1 Scope of Recommended Fuel Management Projects
The scope of the projects encompasses the two parks in the foothills of Palo Alto: Foothills Park and Pearson-
Arastradero Preserve. In addition, treatments along four roads extend outside the parks themselves but are
confined to City boundaries or rights-of-ways: Page Mill Road, Arastradero Road, Los Trancos Road, and
Skyline Boulevard.
4.4.2 Project Description Summary
Fuel management is proposed on 330 acres of Foothills and Arastradero Parks to protect lives, enhance the safety of improvements in and around the parks and to enhance ecosystem health. Fuel management falls into
the following categories: roadside treatments along potential evacuation corridors, creation and maintenance
of firefighter safety zones, creation and maintenance of defensible space around structures in the parks, and treatments to aid containment of fires in and within the park.
Treatments are performed on a rotational basis with intervals of approximately every five years, with an
anticipated area of approximately 100 acres treated annually after the initial treatments are performed.
Vegetation types that will be treated include:
• Grasslands
• North Coastal Scrub
• Chaparral
• Oak Woodland
• Riparian Woodland (limited areas and limited treatment only)
4.4.3 Project Objectives
Projects are justified by various objectives, spanning the need to keep fires from crossing boundaries,
minimizing damage to developed areas and minimizing damage to natural resources. Others comply with regulations, which themselves are intended to increase access, or facilitate fire suppression.
A variety of projects reduce the chance of damage to life and property. There are projects that keep fire from
crossing boundaries, which could be in the form of fuel management to compartmentalize the landscape, or
fuel management along the borders of the parks, or modification of the volume or structure of the fuels to reduce chance of ember production or enhance firefighting effectiveness.
Other projects focus on minimizing damage to developed areas, and may be distinct from efforts to reduce fire
size, particularly where fire growth is in the wildland. Methods to minimize damage to structures would encompass the following actions: stop ember production, manage fuels along borders with structures, anywhere around structures (up to 100 feet), retrofit structures to make them more ignition-resistant, and
enhance firefighting effectiveness.
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While fire is a natural force in the foothills of Palo Alto, fuel management also aims to minimize damage to natural resources within the City of Palo Alto. This may include fuel management around sensitive areas such as riparian corridors, or use of fire where needed for resource management. The skillful application of
controlled burning would be justified where fire exclusion is harmful, for example, where species require fire
for seed germination, or where native grasslands experience brush encroachment, or where an unnatural accumulation of understory fuels (both live and dead) develops. Enhancing firefighting effectiveness, so that
fire response can better apply or restrain fire’s impacts on sensitive natural resources may further justify
projects.
Finally, some projects are further justified by local regulations. For example, the City of Palo Alto regulations require installation and maintenance of 100-ft defensible space around structures, fuel
management for a minimum width of 10-ft along roads, and maintenance of 13.5-ft high vertical clearance
over roadbeds.
4.4.4 Priority
Fuel management is not possible, nor advisable, on every acre of the wildlands in the two City parks. Not even all the areas of high hazard can be treated with a reasonable level of funding, so prioritization needs to
occur. Finding the most effective location and scope is a challenge because of uncertainties around relative
fire hazard, erosion, potential, ignition potential, cost of implementation, environmental impacts of the management itself, and social values attached to the project location.
Selection of fuel treatment areas is based on several factors, including the probability of the event, the
potential damage of that event, ignition locations, adjacency to improvements or other sensitive values at risk
from wildfire, and the propensity of the treatment to aid containment.
4.4.5 Project Locations
The following table (Figure 18) and maps (Figures 19 and 20) summarize the project locations. Each treatment location was selected to achieve a specific objective. Many treatments are associated with
roadsides, structures and City Park/Preserve boundaries. Treatments for containment are strategically located
at ridgetops, in places that have access, are not too steep for mechanical treatments, avoid riparian areas, and are not prone to soil erosion. Sections 4.4.7 through 4.4.13 provide additional information regarding project treatments by project type.
Figure 18: Listing of Project Locations.
Designation Project Description
Life Safety
Foothills Park
F.F1 Firefighter Safety Zone 1 Trappers Ridge & Los Trancos Trail
F.F2 Firefighter Safety Zone 2 Trappers Ridge & Madrone Fire Road
F.F3 Firefighter Safety Zone 3 Trappers Ridge high point
F.F4 Firefighter Safety Zone 4 Trapper Ridge south end
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Designation Project Description
F.E1 Evacuation Route - Page Mill Road Within PA City from Arastradero to southern Pony Tracks
F.E2 Evacuation Route - Park Road Entrance to Maintenance Yard Las Trampas Valley
F.E3 Evacuation Route - Park Northwest Interpretive Center to the 600-700 block of Los Trancos Road
F.E4 Evacuation Route - Park Northeast Boronda Lake to Alexis Drive
F.E5 Secondary Evacuation Route - Wildhorse Valley Wildhorse Valley from Towle Campground to Las Trampas Valley
Pearson-Arastradero
A.E1 Evacuation Route – Arastradero Road Arastradero Road
Off-site
PA.1 Evacuation Route Page Mill Road
PA.2 Evacuation Route Arastradero Road
PA.3 Evacuation on Los Trancos Road between Santa Clara County boundary and Oak Forest Court
PA.4 Evacuation Route Skyline Blvd.
Structure and Infrastructure Protection
Foothills Park
F.D1 Defensible Space Entry Gate and Restroom
F.D2 Defensible Space Station 8
F.D3 Defensible Space Restrooms at Orchard Glen
F.D4 Defensible Space Interpretive Center
F.D5 Defensible Space Maintenance Shop Complex
F.D6 Defensible Space Boronda Pump Station at Campground
F.D7 Defensible Space Park Tank
F.D8 Defensible Space Boranda Water Tank
F.D9 Defensible Space Dahl Water Tank
Pearson-Arastradero
A.D1 Defensible Space Gateway Building and Restrooms
A.D2 Defensible Space Pump Station
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Designation Project Description
A.D3 Defensible Space Corte Madera Water Tank
Ignition Prevention
Foothills Park
F.I1 Ignition Prevention Lakeside Picnic Area
F.I2 Ignition Prevention Shady Cove Picnic Area
F.I3 Ignition Prevention Encinal and Pine Gulch Picnic Areas
F.I4 Ignition Prevention Orchard Glen Picnic Area
F.I5 Ignition Prevention Oak Grove Group Picnic Area
F.I6 Ignition Prevention Towle Camp
Containment
Foothills Park
F.C1 Containment Trappers Trail
F.C2 Containment Pony Tracks south of Trappers Ridge
F.C3 Containment Pony Tracks north of Trappers Ridge
F.C4 Containment Bobcat Point
F.C5 Containment North of Entry Gate
F.C6 Containment Valley View Fire Road
Pearson-Arastradero
A.C1 Containment Property boundary adjacent to Liddicoat
A.C2 Containment Property boundary adjacent to Stanford and Portola Pastures
A.C3 Containment Redtail Loop Area
A.C4 Containment Property boundary adjacent to Paso del Robles
A.C5 Containment Property boundary Laurel Glen - north
A.C6 Containment Property boundary Laurel Glen - south
A.C7 Containment Property boundary west of Meadow Lark Trail
A.C8 Containment
Property boundary adjacent to former private research
facility
A.C9 Containment Property boundary adjacent to John Marthens Lane
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Designation Project Description
A.C10 Containment Arastradero Creek (to Juan Bautista trail)
A.C11 Containment Meadow Lark to Juan Bautista Trail
A.C12 Containment Meadow Lark south
A.C13 Containment Bowl Loop Trial
A.C14 Containment Arastradero to Rx fire area
A.C15 Containment Acorn Trail
A.Rx1 Containment Juan Bautista Prescribed fire north
A.Rx1 Containment Acorn Trail Prescribed fire south
Figure 18: Listing of Project Locations.
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Figure 19: Proposed Treatment Locations in Pearson-Arastradero Preserve.
January 2009
A D 2
A D 3
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Draft (15 January 2009) 52
Figure 20: Proposed Treatment Locations in Foothills Park.
FI1 FI2
January 2009
FD8
FD1000
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Draft (15 January 2009) 53
4.4.6 Project Dimensions and Post-Treatment Standards
The dimensions of the treatments follow in the table below (Figure 21). The treatments that will occur within
the project area depend on the vegetation type and treatment method. The post-treatment standards for each treatment type and a description of the treatment methods are also included.
Project Types Dimension Treatment Frequency Comments
Roadside Treatments
Major evacuation
routes
30 feet on both sides of pavement edge Rotate 3-5+ years depending
on fuel type
Annual for first 10 feet with
grass fuels
Secondary evacuation routes 15 feet on both sides of pavement edge Rotate 3-5+ years depending on fuel type
Defensible Space 100-ft from structure Annual Follow-up treatments may not
be required annually
Ignition Prevention 10-ft from barbeque Annual
Firefighter Safety Zones 100-ft radius Annual
Containment Fuel Breaks
Area treatment Within 300-ft of ridgetop of Trappers Ridge Rotate 3-5+ years
Areas designated goat grazing within park Rotate 3-5+ years
Two designated potential prescribed burn units per map Rotate 3-5+ years
Perimeter treatment
Brush/understory In designated areas within 300 feet of park boundary Rotate 3-5+ years
Grass Discing or mowing 15-45 feet from park boundary, as practical Annual
Eucalyptus Removal Individual tree removal One time Follow up to ensure no stump
sprouts
Figure 21: Treatment Methods and Intervals.
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4.4.7 Roadside and Driveway Fuel Modification for Safe Access and Egress
4.4.7.1 Specific Goal of Action
The most important goal for this set of projects is to reduce fire intensity near roads to allow firefighting
vehicles to pass and ensure safe passage for staff and visitors to pre-determined safety zones, or safe locations out of the parks. In addition, the projects outside of the City parks/preserves are aimed at facilitating access
and egress between different portions of Palo Alto’s wildland urban interface.
4.4.7.2 Location and Description of Projects
Projects would be located along roads and driveways of varying width, depending on whether the road is a major or secondary evacuation route.
• 10 feet where flames are predicted to be less than eight feet in length (generally in grassy locations
and in oak woodlands), such as along Wildhorse Valley in Foothills Park.
• 30 feet from pavement edge along major evacuation routes that are Page Mill Road, Los Trancos
Road, Arastradero Road, Skyline Boulevard, and the road from the Foothills Park Entry Gate to the
Maintenance Shop.
Palo Alto should work cooperatively with Los Alto Hills, the Town of Portola Valley, CalTrans, San Mateo
County, Santa Clara County, and other agencies to ensure vegetation along Page Mill Road, Arastradero
Road, Los Trancos Road, and Skyline Blvd. are mowed, trees are maintained, and other treatments are implemented and sustained.
Figure 22 lists the location and description of proposed safe access and egress projects. Figure 23 provides a
graphical representation of major evacuation routes that are external to the two preserves.
Designation Project Description Distance Treatment Method
Foothills
F.E1 Page Mill Road Within PA City from Arastradero to southern
Pony Tracks
13,855 ft mowing, grazing, hand
labor
F.E2 Evacuation Route - Park Road
Entrance to Maintenance Yard Las
Trampas Valley
7,211 ft mowing, grazing, hand labor
F.E3 Evacuation Route -
Park North west
Interpretive Center to
the 600-700 block of Los Trancos Road 1,263 ft mowing, grazing, hand
labor
F.E4 Evacuation Route - Park North east Boronda Lake to Alexis Drive 2,618 ft mowing, grazing, hand labor
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F.E5 Secondary Evac Route Towle Campground to
Las Trampas Valley 2,818 ft mowing, grazing, hand
labor
Pearson-Arastradero
A.E1 Evacuation Route Arastradero Road 6,337 ft mowing, grazing, hand labor
Off-site
PA.1 Page Mill Road From Foothill Park South to Skyline Blvd. 11,980 ft mowing, grazing, hand labor
PA.2 Arastradero Road
From Page Mill to Arastradero Pk, and
from Arastradero Pk to Los Trancos
940 ft mowing, grazing, hand
labor
PA.3 Evacuation Route -
Los Trancos
Los Trancos Road between Santa Clara
County boundary and
Oak Forest Court
4,406 ft mowing, grazing, hand
labor
PA.4 Skyline Blvd. Skyline Blvd.3 7,907 ft mowing, grazing, hand labor
Figure 22: Listing of Project Locations for Evacuation and Access.
3 CalTrans is responsible for treatments within the designated right-of-wa,y which is variable in width (generally 2-
30-ft). Regardless the City of Palo Alto is committed to conduct treatments on City lands adjacent to the road.
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Figure 23: Evacuation Routes External to Foothills Park and Pearson-Arastradero Preserve.
Vegetation maintenance on Highway 35 is the responsibility of CalTrans
P A 3
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4.4.8 Fuel Modification for Firefighter Safety Projects
4.4.8.1 Specific Goal of Action
This project goal is specific to the safety of firefighters during emergency response. In times of emergency, a
safe refuge comprised of low fuels is vital.
4.4.8.2 Location and Description of Projects
These projects would install and maintain four firefighter safety zones within Foothills Park. Specifically,
they are located on the Trappers Trail fuel break, at Los Trancos Trail, Madrone Fire Road, at the high point
on Trappers Ridge and the south end of Trappers Ridge.
Designation Project Description Acreage Treatment Method
Foothills
F.F1 Firefighter Safety
Zone 1
Trappers Ridge & Los
Trancos Trail > 1 acre mow, graze
F.F2 Firefighter Safety
Zone 2
Trappers Ridge &
Madrone Fire Road > 1 acre mow, graze
F.F3 Firefighter Safety
Zone 3
Trappers Ridge high
point > 1 acre mow, graze
F.F4
Firefighter Safety Zone
4 Trapper Ridge south end > 1 acre mow, graze
Figure 24: Listing of Project Locations for Fire Fighter Safety Fuel Modification.
4.4.9 Structure and Infrastructure Projects – Defensible Space
4.4.9.1 Specific Goal of Action
• Reduce damage to structures, developed areas and critical infrastructure from wildfire by reducing
flame length to two feet within 30 feet of structures by managing fuels per Defensible Space
Guidelines in Section 1.6.8. In some cases, treatment will need to extend to 100 feet in order to reduce flames to two feet within thirty feet of a structure.
• Minimize negative effects of fuel manipulation on wildlands
• Reduce damage to wildlands from wildfire
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4.4.9.2 Location and Description of Projects
This vital suite of projects is located generally within 100 feet from structures that are currently in use, which includes entry gates, interpretive centers, restrooms, and maintenance or infrastructure facilities. Some of the
projects are to protect the water and electrical services provided to the park. In addition, fire-resistant features
should be installed when these structures are remodeled or repaired. The structures in the Parks/ Preserve can
serve as a demonstration of the types of actions that should occur in private yards as part of compliance with local codes and ordinances. The following lists specify which structures need defensible space established and
maintained annually:
The area around structures is currently treated, however the actions recommended will bolster survivability of structures.
Designation Project Description Acreage Treatment Method
Foothills
F.D1 Defensible Space Entry Gate and
Restrooms > 1 acre hand labor
F.D2 Defensible Space Boranda Water Tank > 1 acre hand labor
F.D3 Defensible Space Restrooms at Orchard Glen > 1/2 acre hand labor
F.D4 Defensible Space Interpretive Center > 1 acre hand labor
F.D5 Defensible Space Maintenance Complex > 1 acre hand labor
F.D6 Defensible Space Boronda Pump Station at
Campground > 1 acre hand labor
F.D7 Defensible Space Park Tank > 1/2 acre hand labor, grazing
F.D8 Defensible Space Station 8 > 1/2 acre hand labor, grazing
F.D9 Defensible Space Dahl Water Tank > 1/2 acre hand labor, grazing
F.D10 Defensible Space Oak Grove Restrooms > 1/2 acre hand labor, grazing
Pearson-Arastradero
A.D1 Defensible Space and
Restrooms Gateway Building > 1 acre hand labor, mowing
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A.D2 Defensible Space Corte Madera Pump Station > 1 acre hand labor, mowing
A.D3 Defensible Space Water Tank > 1 acre hand labor, mowing
Figure 25: Listing of Project Locations for Defensible Space.
4.4.10 Ignition Prevention Fuel Management Projects
4.4.10.1 Specific Goal of Action
Ignitions from barbeques may occur in Foothills Park. Ignition prevention relies upon fuel management,
coupled with education, signage, and enforcement of park rules regarding fire safety. Under extreme fire
weather conditions, the parks may be closed to the public. The fuel management will consist of the following:
• Follow standards for defensible space for a 30-ft radius from the barbeque site.
• Remove vegetation to create a non-combustible zone for a 10-ft radius from the barbeque site.
4.4.10.2 Location and Description of Projects
Designation Project Description Acreage Treatment Method
Foothills
F.I1 Ignition Prevention Shady Cove Picnic Area > 1/4 ac hand labor
F.I2 Ignition Prevention Encinal Picnic Area > 1/4 ac hand labor
F.I3 Ignition Prevention Pine Gulch Picnic Area > 1/4 ac hand labor
F.I4 Ignition Prevention Orchard Glen > 1/4 ac hand labor
F.I5 Ignition Prevention Oak Grove Group Picnic Area > 1/4 ac hand labor
F.I6 Ignition Prevention Towle Camp > 1/4 ac hand labor
Figure 26: Listing of Project Locations for Ignition Prevention.
4.4.11 Fuel Modification for Containment Ease
4.4.11.1 Specific Goal of Action
The specific goal of modifying fuels in the two parks is to compartmentalize fuels in order to facilitate the containment and control of a fire. The treatment areas are positioned in strategic locations, usually on a
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ridgetop, with access, avoiding areas that would preclude the use of mechanical equipment such as steep slopes or riparian areas. Fuels are modified to reduce fire intensity and thus allow firefighters better access to the fire, making firefighting actions more effective. Fuel modification also creates more opportunities to
backfire, which occurs during wildfires where fire suppression crews create large firebreaks in advance of the
fire front. Fuel modification can also slow the spread of a fire, further enhancing fire control efforts. Where trees abut grasslands in the new fuel breaks, it is especially important to limb trees and remove shrubby
understory from trees along the edge of the forest canopy in order to break vertical continuity between grass
and tree canopy. This action will remove the “ladder fuels” that promote crown fires and hinder fire
containment.
4.4.11.2 Location and Description of Projects
In Pearson-Arastradero, the projects entail discing and mowing along the grassy perimeter of the preserve,
and grazing in the shrubby areas that abut residences. Grazing of shrubby areas near residences need not
occur every year, but rather on an approximate three-year rotation. Strips of grass along selected trails are likewise recommended for mowing to enhance containment and access. Two prescribed fires are
recommended in the interior of the preserve as another means to remove fuels to reduce wildfire intensity and
aid containment during a wildfire.
In Foothills Park, a series of fuel breaks are recommended in shrubby fuels. In the fuel breaks, a rotation of treatments is recommended. The fire roads would be graded annually, and grass mowed within 10-3 0 f e e t o f
the road. Additional mowing/brush cutting would extend to the break in topographic slope, which could be
located as far away from the road as 200-ft. This type of mowing would occur in any one location approximately every 3 years; the intent is to maintain the area in a mixture of grass with less than 30 percent
canopy cover of shrubs. While treatments may vary over time, the recommended rotation is between rest,
mowing/brush cutting and grazing.
Designation Project Description Acreage or Distance Treatment Method
Foothills
F.C1 Containment Trappers Trail 72.51 acres mowing, grazing
F.C2 Containment Pony Tracks south of
Trappers Ridge 2,975 ft
mow annually 10-ft on
either size of road, use a brush hog (or grazing
animals) to mow areas to the break in slope both
under wooded canopy and in grasslands with cover of
coyote brush greater than
30%
F.C3 Containment Pony Tracks north of
Trappers Ridge 2,461 ft mowing, grazing
F.C4 Containment Bobcat point 5.28 acres graze with goats
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F.C5 Containment North of entry Gate 3.47 acres graze with goats
F.C6 Containment Valley View Fire Trail 1,459 ft mowing
Pearson-Arastradero
A.C1 Containment Property boundary
adjacent to Liddicoat 5.39 acres grazing, mowing
A.C2 Containment
Property boundary
adjacent to Stanford and Portola Pastures 5,371 ft grazing, mowing
A.C3 Containment Within Redtail Loop Trail, to entire eastern
boundary of Preserve
48.72 acres grazing
A.C4 Containment
Property boundary
adjacent to Paso del Robles 7.71 acres grazing
A.C5 Containment Property boundary
Laurel Glen - north 11.22 acres grazing
A.C6 Containment Property boundary
Laurel Glen - south 4.05 acres grazing
A.C7 Containment Property boundary west
of Meadow Lark Trail 9.71 acres grazing, mowing
A.C8 Containment
Property boundary
adjacent to 1791 Arastradero Rd. 8.08 acres grazing (mowing is not
possible)
A.C9 Containment Property boundary adjacent to John
Marthens
1,726 ft mowing
A.C10 Containment Arastradero Creek to Arastradero Road 10,222 ft mowing, hand labor near riparian zone
A.C11 Containment Meadow Lark to Juan Bautista Trail 8,893 ft mowing
A.C12 Containment Meadow Lark 1,569 ft mowing
A.C13 Containment Bowl Loop 1,388 ft mowing
A.C14 Containment Arastradero to extended split RX1 and RX2 1,830 ft mowing
A.C15 Containment Acorn Trail 1,218 ft mowing
Figure 27: Listing of Project Locations for Containment Ease.
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4.4.12 Fuel Modification for Ecosystem Health
4.4.12.1 Specific Goal of Action
Only a few projects that benefit ecosystem health as their primary justification have been identified in this
phase; however, many of the other projects enhance natural resources while achieving other management goals. In all cases, the goal of the action is to restore a species distribution and volume of biomass to a
condition of effective fire suppression through grazing and prescribed fire.
The City should conduct fuel modification to reduce the invasion of coyote bush into grasslands and thus reduce expected heat output. The project located along Trappers Trail consists of mowing chaparral on a rotational basis every two-to three years. This will release native grasses, produce more food for wildlife and
provide diversity of age and vegetation structure. Another project is to re-introduce fire in the grasslands of
Pearson-Arastradero through prescribed burning a selected interior area on a rotational basis. In both cases, the objectives are to maintain grasslands and restore the native pattern of vegetation on the landscape. A third
project to enhance ecosystem health is to graze, with sheep or goats, broad areas that are currently being
mowed for grass and invasive weed management.
Other fuel management projects also enhance ecosystem health. Reducing the amount and height of understory shrubs creates a vegetative structure that is more open at the forest floor, with less biomass and is
vertically discontinuous; this mimics the pre-fire-suppression era. This would be done either with goat herds
or with hand labor forces.
4.4.12.2 Location and Description of Projects
Designation Project Description Acreage Treatment Method
Foothills
F.C1 Containment Trappers Trail 72.51 acres mowing, grazing
Pearson-Arastradero
A.Rx1 Containment Juan Bautista Prescribe
fire north 18.25 acres Rx fire, grazing
A.Rx2 Containment Acorn Trail Prescribed
fire south 24,45 acres Rx fire, grazing
A.C3 Containment Within Redtail Loop Trail, to entire eastern boundary of Preserve 48.72 acres grazing, mowing
Figure 28: Listing of Project Locations for Ecosystem Health.
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4.4.13 Cooperative Fuel Management Projects for Offsite Fire Containment
and Evacuation Ease
4.4.13.1 Specific Goal of Action
The goal of this project is to prevent a wildfire from spreading into the parks. The City should work with
adjacent landowners to institute and maintain the vegetation in a condition that would facilitate containment
and ease evacuation operations.
Another cooperative project would be to work to reduce the frequency and impact of sudden oak death,
particularly on the western edge of Palo Alto.
4.4.13.2 Location and Description of Projects
Cooperation with neighbors is important in the installation and maintenance of fire-safe conditions on lands adjacent to or near the City parks. Most importantly, the enhancement of roadside treatments along Page Mill
Road requires cooperation with several other landowners and agencies, as enumerated previously.
Cooperative projects also include the formalization of agreements for passage through properties during time
of emergency evacuation with public and private land owners and managers. The City should develop partnerships to address regional evacuation routes from residential and public areas, as detailed in the
following section. Cooperative projects also include fuel management on City-owned open space adjacent to
private structures. In some cases, such as on the western edge of Foothill Park east of Carmel and Ramona Road in Los Trancos Woods, access through private parcels would enable fuel management on City lands that
would benefit both parties involved.
Sudden Oak Death has been observed in many locations within the Foothills area. At this time the areas are
small and consist of one or two trees. The urgency for treatment of these affected areas is related to its location. Dead trees near structures, City property boundaries and along roads should be treated first. For
example, dead trees along evacuation routes would get higher priority than those in the middle of remote
woodland. However, if entire stands die, or sudden oak death changes the fuel characteristics of the stand, the priority and potential treatments would change. The location and extent of stands affected by Sudden Oak
Death should be monitored.
Treatment should be consistent with the City policy regarding Sudden Oak Death. Treatments generally
entail removal of dead material smaller than six inches in diameter. The trunks of the trees may remain if needed for wildlife habitat, however it is often difficult to retain just the larger material. The proximity of
California bay to the foliage of oaks has been linked with the spread of Sudden Oak Death. Removal or
trimming of bay trees to separate the foliage is another strategy to prevent further spread.
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5 IMPLEMENTATION PLAN
However valuable and imperative the plan may be, implementation is the key to achieving the goals set forth
by the plan. There are several recommendations that can facilitate implementation of the fire management
plan.
5.1 Implementation Strategies
The creation of an Implementation Team within the City staff will support implementation. The team would
benefit from representatives that could help with project design, cost estimation and budgeting, evacuation planning, and community outreach. The team would include in its mission development of educational
material for the community. Implementation Team should include staff from the City Manager's Office, the
Fire Department (Chief, Operations, Fire Marshal, CERT), the Police Department (Chief, Homeland Security,
Communications/Dispatch, PIO), the Planning Department, Open Space/Parks, Public Works, and Utilities.
The City should support the formation of a Midpeninsula Foothills Emergency Forum (MFEF). The MFEF
would collaborate on resource management issues. The scope would include pursuit of grants, equipment and
resource sharing (such as mechanical equipment and expertise) and joint design of projects especially on City boundaries, or along co-owned/managed roads. The City should work with stakeholder/ partners on common issues. For example, Los Altos Hills, Stanford, Los Trancos Woods, Los Trancos Water Department,
MROSD, and private neighbors all have concerns and potentially partial solutions for access and egress
constraints. Each partner may have a particular asset to contribute, whether it is available funds or ready volunteers, or expertise in the subject of need. Collaboration creates a stronger base from which fruition of
the plan can more readily occur.
This interagency organization would be separate from the existing FireSafe Councils; participation would
include CEO-level discussions and staff liaisons from each participating agency.
The City should participate in local FireSafe Councils, in both Santa Clara County and San Mateo County4.
FireSafe Councils can help in obtaining federal funds because the local FireSafe Councils have an already-
written Community Wildfire Protection Plan, which is a prerequisite for national funding. Interagency collaboration is also fostered by FireSafe Councils. The local San Mateo FireSafe Council also facilitates
access to the use of subsidized California-youth authority hand labor crews. These crews have a long track
record of successful fuel management projects at surprisingly low costs. The San Mateo FireSafe Council
also has a chipping program to alleviate the burden of disposing of biomass from fuel management projects.
The City should also implement projects in City park/preserves through its regular budget process. The City
has a history of fuel management that should be continued. Fuel management will continue to be funded
through the normal budget process, to encompass continued mowing, occasional grazing, maintenance of defensible space around structures and resource enhancement projects.
Funding specific prescribed burns is also expected through the budget process if not funded by grants or
conditions tied to this project. For example, a prescribed burn in Alameda County was required as a
mitigation measure for a necessary project to expand a facility near a creekbed. Similarly, projects that
4 Participation in the San Mateo County FireSafe Council would be as an interested party but not to take
official action or receive any financial benefit.
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enhance natural resources can be used as mitigation measures for worthwhile projects that may have negative impacts.
While it is not expected that the City would make a profit from natural resources, the value of its grasslands as
feed could be used to offset the cost of using livestock as a resource management tool. Similarly, the City
should make an effort to obtain value from wood recovered from dead tree removal, potentially though innovative wood-based art projects.
The City has a rich bank of volunteer groups; projects could be implemented with the help of volunteer
groups. Relationships with stakeholders such as Acterra, Friends of Foothills, 4-H, and other should be
fostered. Roles for these groups could include the performance of pre-treatment surveys, construction and placement of raptor perches, support of grazing operations (movement of portable livestock fences or water
sources), or distribution of educational and evacuation directional signs. Corporate volunteerism can be
directed to fuel management projects.
The adoption of new codes may be less obvious than the implementation of specific projects. Regardless, the
adoption of recommended changes in the City code may have more long-lasting and far-reaching effects
throughout the City. These recommendations should be pursued.
Similarly, the continuation of Station 8 staffing should be viewed as a part of the implementation of this plan.
5.2 Priorities
The priority of the projects has been emphasized earlier in this report. Life safety concerns – those focusing on egress and emergency response access – are the highest priority. The projects that address this objective
should be immediately pursued. The maintenance of firefighter safety zones is similarly high in priority.
Fuel management projects that prevent the ignition of structures are of the next highest priority. This would
include the maintenance of defensible space around City structures and vital infrastructure facilities. These projects are mandated by law. Fuel management to prevent the spread of fires to off-site structures from City
property are within a level of reasonable care expected from a City; these projects are also considered a type
of containment project.
Fuel management that promotes containment of fires within City property is next in priority. These projects support the response to infrequent, yet potentially catastrophic fires. In addition, these fuel management
projects prevent the more ordinary events from becoming catastrophic.
Projects that enhance natural resources are difficult to fund. However, fuel management offers occasions to both enhance natural resources and fire safety. Every fuel management project should be viewed as an
opportunity to simultaneously enhance natural resources and promote fire safety.
The following criteria (not ordered by importance) can help determine the schedule of recommended fuel
treatment project:
• Benefit of project in minimizing structure damage or chance of damaging wildfire.
• Probability of damaging wildfire (based on fuel loading and vegetation structure).
• Potential for ecological benefit (or damage without fire).
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• Divergence of fuel loading and vegetation structure from natural conditions (i.e. deviation from natural fire regime).
• A window of opportunity, based on funding timelines, availability of personnel or equipment, or other factors.
• If using prescribed fire, some areas may need to be burned in a particular sequence to minimize the
potential for escape.
5.3 Fuel Management Project Costs
Costs are variable, depending on the project design, site features, access, requirements for insurance, traffic
and fencing control, staging, move-in costs, bonding, administration, wage reporting and other city requirements, such as governing regulations, or resource restrictions (i.e. species of concern).
Considering only the direct project-related costs, the unit costs of various treatment methods can vary
dramatically between the types of treatment methods, but within the treatment methods as well. Similarly, the site conditions, weather, and other external factors that affect unit costs of some treatment methods are:
• Height, density, species, and arrangement of existing vegetation;
• Desired vegetation conversion and management objectives;
• Size, accessibility, slope, soil stability, and vegetation types onsite;
• Need for multiple treatment types at a site over a short period of time (cumulative costs); and
• Planning and monitoring to develop follow-up treatment prescription.
The following table describes unit costs associated with the treatment methods.
Treatment Method Estimated Unit Cost ($ per Acre) Notes/Other Considerations
Hand Labor Treatments
Weed Whipping 1,500
Chaparral Brush Removal 2,140 a
Hand-Pulling 2,000
Vista Pruning $1/linear ft / 50-250 b Roadside treatments – no shrubs
Mosaic/Drip-Line Thinning $2/linear ft / 3,500 a Roadside treatments with shrubs
Organic Mulch 575-1,600 b,c Same as chipping/mulching
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Treatment Method Estimated Unit Cost ($ per Acre) Notes/Other Considerations
Mechanical Treatment
Grading 500-600 b,c
Mowing 500-600 b,c
Chipping/Mulching 575-1,600 b
Roadside Mowing with Shrubs $1/linear ft
Prescribed Burning
Broadcast Burning 60-400 b Fixed costs are high, should use $25,000 per burn rather than per-
acre costs
Grazing
Sheep 200 b
Goats 500
Chemical Treatment
Stump Application 200
Foliar Application 500
Figure 29: Unit Costs for Fuel Reduction Treatment Methods.
a The Sea Ranch Association Fuels Management Implementation, 2002 confirmed 2008.
b Applegate, Oregon Fire Plan. http://www.wildfireprograms.com/search.html?displayId=237
c Fire Plan, http://www.wildfireprograms.com/search.html?displayId=237
5.3.1 Project Cost Estimates
The following is a compilation of cost estimates for the 51 recommended treatment areas in Pearson-
Arastradero Preserve and Foothills Park, and along selected segments of major evacuation routes in the City
of Palo Alto. The total five-year cost amounts to approximately $700,000.
Costs of Firefighter Safety Zones = $800 annually
The costs of each firefighter safety zone was estimated as $200 per zone, based on the cost to mow a grassy
area of approximately one acre in size. Mowing costs of unobstructed grass are approximately $200/hr,
which includes the cost of the machinery and operator, and a spotter. The production rate of area mowing is approximately one acre per hour. This cost does not include move-in costs, because it assumes the mowing
for firefighter safety is part of a larger mowing contract.
Because the safety zones need to be treated annually, the cost of treating all the firefighter safety zones is $800 per year.
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Costs of Initial Treatment along Evacuation Routes = $192,960 initial treatment, $86,400 total for the
subsequent 4 years56
The treatment along roads identified as evacuation routes would include a mixture of machinery-based mowing (including mowing with an articulated brush-cutting head that cuts brush) and the use of hand labor.
In circumstances where wider areas can be treated, grazing animals, principally goats, can be used to perform
initial treatments along evacuation routes.
The total length of evacuation routes is slightly more than 12 miles, or 63,740 linear feet, which encompasses
those areas highlighted in blue on Figures 17 and 18 and in Section 4.4.7.2.
The estimate of costs for this type of treatment assumes an operation that would use the machinery wherever
possible as a cost containment measure. One can assume one-half of the length can be treated with machinery for the first 10-ft off the roadside. The remainder of the area would need to be treated by hand.
Estimates are based on treating both sides of the road for 30-ft, or a 60-ft wide strip, or almost 24 miles of
linear treatment. Treatment recommendations state that areas of oak woodland need be treated for only 10-ft in width because expected fire behavior is relatively calm; however, for cost estimates, every length of the roads were estimated being treated for 30-ft width.
The most inexpensive treatment is roadside mowing of grassy areas with few shrubs or trees. This is expected
to occur on approximately ¼ of the length of the roadside, for the first 10-ft off the road. Roadside mowing of grass expected to cost approximately $200/hour for the machinery, operator and spotter; production rates
generally run around 300 linear feet per hour, or a little less than 18 hours to treat a mile. Production is
reduced by the need to pick up the cutting head to move to a new site, and the need to avoid areas of trees.
Using this production rate, mowing of approximately 108 hours, or for a cost of $21,600.
The next most cost-effective treatment is use machinery to cut roadside shrubs within the first 10-ft of the road. Shrubs near the roads are more common, occurring on approximately ½ of the length of the roads. A
cost of $200/hr for the machinery, operator and spotter is used. Production is reduced to 200 linear feet per
hour, requiring 26.4 hours to cut brush for a mile. A little more than 316 hours would be required to treat the
estimated 12 miles of shrubs, for a cost of $63,360.
Machinery has the potential to start fires from causing sparks in dry vegetation. A dedicated fire watch for
the operation during fire season is recommended, at an additional cost of $15,000, based on 214 hours of
operation during fire season, assuming one-half of the machinery-based work is performed during fire season.
The remainder of the treatments will require hand labor to remove shrubs, limb the lower branches of trees smaller than three inches in diameter. This would be required on ¼ of the first 10-ft of the roads, and the
entirety of the remaining 20 feet off main evacuation routes.
Hand labor crews with a supervisor typically cost $1200/day. The production rate for this type of tree
limbing and shrub removal is one-tenth of an acre each day, or $10,000 per acre. Subtracting the areas treated with mechanical equipment, approximately 93 acres will need to be treated using hand labor crews, at a cost
of $93,000.
5 Personal communication with J. Squadroni, of Environtech, January 2009, regarding roadside treatment costs. These cost were confirmed,
based on worked performed by Environtech, including roadside treatments on Los Trancos Road in early 2000’s and in Carmel Valley m o r e
recently.
6 Personal Communication with Mike Philbin, Central Coast Land Clearing, October, 2008. Cost estimates based on work performed in 2008 on
roadside treatments in Carmel Valley and in Santa Cruz County.
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Government-subsidized hand crews that utilize people in the California Youth Authority system can result in dramatic cost reductions. Costs of hand labor crews can be reduced by a factor of ten.
Maintenance would consist of mowing the first 10-ft from the pavement edge yearly, at an annual cost over
the next four years of $21,000 per year.
Costs of Maintaining Defensible Space around Park/Preserve Structures and Infrastructure = $17,800
Treatments to maintain defensible space around each of the structures and infrastructure facilities in the City Park/Preserve entail the use of hand labor to limb trees, remove shrubs under trees, and to mow grass. Some
of the structures, such as the Gateway interpretive Center in Pearson-Arastradero Preserve, have little tree
cover so mowing would comprise the treatment. Others, such as the pumping station in Pearson-Arastradero will require a higher level of effort because of a greater volume of shrubs and trees within 100 feet of the
structure. Limbing and shrub removal need to only be done on a five-year interval, however mowing is
required annually.
The treatments encompass the red solid circles on Figures 17 and 18 and those described in Section 4.4.9.2.
Generally the area of treatments ranges from ¼ acre to 1 acre. Mowing of the area around the structures is
estimated as $100/structure, performed annually. Using hand labor to remove shrubs under trees and to
remove lower branches of trees is estimated as $1,500/acre, performed every five years. There are nine structures identified in Foothills Park, with a total estimated cost of $14,100 over the next five years; Pearson-Arastradero Preserve has four such structures, with an accompanying $3,700 cost for treatment during the
next five years.
Costs of Creating/Maintaining Containment Areas $403,486
Containment Areas in Foothills Park
Treatments to enhance the actions to contain fires span two different shapes and sizes of treatments. Area treatments are recommended in Foothills Park for Trappers Trail, the Pony Tracks South of Trappers Ridge,
the Bobcat Point Containment Zone and the area north of the Foothills Park Entry Gate. Shrubs and lower
tree branches should be trimmed within the containment areas on a three-year interval of time. The grass in Trappers Trail and Pony Tracks South of Trappers Ridge will be mowed every three years, with the exception
of a width of 30 feet on both sides of the graded trail. Shrubs in the Bobcat Point Containment Zone and the
North of Entry Gate Containment Zone are recommended to be treated every five years. Grass in the other
containment zones is to be mowed annually in order to bolster containment efforts during fire suppression.
Trappers Trail Containment Zone – 72.5 acs. The cost estimate of treatment is based on a rotation of
treatments on a three-year cycle, and an annual treatment of mowing of a band of grass for a 30-ft width on
both sides of the graded trail. One third of the area would be mowed in any year. One-third grazed, and one-third left to re-grow. This rotational treatment will allow more forage and cover for wildlife, and provide greater diversity of plants and vegetation structure. The cost of grazing one-third of the area, or roughly 25
acres, is estimated at $500/acre, or a total annual cost of $12,500. Costs of grazing are estimated to be lower
than other areas because grassy nature of the area will facilitate fencing. Mowing is similarly lower in cost, at $500/acre, or an annual cost of $12,500, also because of previous treatments on the site. The total annual
treatment cost for this area would be $25,000, or $125,000 combined for the next five years.
Pony Tracks South of Trappers Ridge Containment Zone – 7 a c . The cost estimate of treatment is also based
on a rotation of treatments on a three-year cycle, and an annual treatment of mowing of a band of grass for a 30-ft width on both sides of the graded trail (if the area is not grazed). Because of the small size of the
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treatment area, the entire area can be mowed one year, grazed another, and left to rest a third. Using mowing
and grazing costs of $500/acre, the five-year cost of treatment would be $14,000.
Pony Tracks North of Trappers Ridge Containment Zone – 2460 ft. The treatment cost is based on annual
mowing along both sides of the graded trail. Using the production rate of 300 feet per hour and an hourly cost
of $200/hr for an equipment operator and spotter, the cost of this treatment is estimated at $1640, or $8,200
for the next five years.
Bobcat Point Containment Zone – 5.5 acs. Costs for grazing this treatment area with goats are estimated at $700/acre because the area has not been previously treated and fencing may be challenging. This would
result in a cost of $3850. The treatment interval is recommended to be 5-y e a r s , s o t h e 5 -year cost of treatment
would total $3,850.
North of Entry Gate Containment Zone - 3.5 acs. This area is similar in its treatment recommendation to the Bobcat Point Containment Zone. Grazing costs are estimated at $700/acre, with a 5-year interval between
treatments. The one-time treatment cost is $2,450, as is the 5-year treatment cost.
Valley View Fire Trail Containment Zone – 1460 ft. The treatment cost is based on annual mowing along
both sides of the graded trail. Using the production rate of 300 feet per hour and an hourly cost of $200/hr for
an equipment operator and spotter, the cost of this treatment is estimated at $1,000, or $5,000 for the next five years.
Containment Areas in Pearson-Arastradero Preserve
In Pearson-Arastradero Preserve, fifteen areas are recommended for treatments to facilitate containment
during fire suppression. Of these, seven are areas where grazing is recommended, with a total acreage of
almost 95 acres. The size of the areas to be grazed ranges from slightly more than four acres to almost 50 acres. Of the area to be grazed, 54 acres is comprised of grass, with few fencing challenges. However,
smaller areas that amount to 41 acres to the south and west on the Preserve border are shrubby and have not
been previously treated. Given the variability of the condition, the cost for grazing is estimated at $500/acre, or a total initial cost of $47,500. The grassy areas should be grazed annually, at a cost of $135,000. The
shrubby areas need by treated only once every five years, at a cost of $20,500. The five-year cost thus totals
$155,500.
Mowing the grass on both sides of graded trails is a recommended annual treatment. The linear length of this treatment is 26,846 feet, or slightly more than 5 miles. Using the production rate of 300 feet per hour and an hourly cost of $200/hr for an equipment operator and spotter, the cost of this treatment is estimated at
$17,897, or $89,486 for the next five years.
Two areas are recommended as suitable for a prescribed burn to facilitate containment and enhance natural
resources. The costs for this treatment method are especially difficult to estimate because some of the operation serves as training. Often, adjacent agencies provide additional equipment and resources at no cost.
A large portion of the costs associated with prescribed burning is involved in planning and obtaining the
necessary permits, notification of appropriate agencies and the public and reporting of the results of the burn. Because of the uncertainty regarding the cost, an estimated cost of $25,000 per burn is set. An interval of 5 years is recommended, so a five-year cost for the two treatment areas would total $50,000.
Costs of Conducting Pre-Treatment Surveys = $100,000
Pre-treatment surveys and post-treatment follow-up are part of the best management practices associated with
the recommended treatments. The cost for the pre-treatment surveys and post-treatment follow-up is
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estimated at $20,000/yr, or $100,000 for the total 5-year cost. This cost can be reduced if knowledgeable
volunteers are involved in the survey or monitoring efforts. Estimates for the survey costs assume the City identifies treatments planned for the year and contracts with a biological consulting firm to perform targeted
surveys in the treatment areas.
5.4 Funding Strategies to Support Fuel Management
Multiple funding sources provide greater stability, more funds, increased continuity, more stakeholders, the
potential to expand the scope of work. Each funding mechanism has unique requirements, strengths and
weaknesses. Some are best suited for one-time expenditures such as capital improvements while others are aimed at ongoing maintenance activities. The “strings” attached to each mechanism should be considered. It is advisable to match funding mechanisms with priority projects.
Figure 30: Funding Mechanisms.
A key to expanding funding mechanisms is to demonstrate the value of the projects. Highlighting the value
of fuel management is effectively done at a grass-roots level, through collaboration with stakeholders. This is especially important for mechanisms that require community-wide support through votes or donations of money or in-kind services.
The discussion under Section 8.1 Implementation Strategies discusses the importance of partnering with other
agencies, the use of volunteers to leverage City funds, and the funding of fuel reduction work through the normal budgeting process. This is the most common locally-controlled source of funds, often covering
education, code adoption, and capital improvements. While this seems to be the most reliable long-term
source of funds, even self-funding projects are vulnerable to a shift in priorities (because these projects need to compete with other community public service needs) or a downturn in economic markets.
Funding projects with grants requires that the City match projects with funding sources. Creativity can yield
surprising avenues for funding. For example, funds from Homeland Security may be justified to purchase
equipment that washes off weed seeds from vehicles because of concerns about decontamination. In this case the same equipment can be used as a solution to disparate concerns.
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Bonds may be used for capital improvement projects, especially related to evacuation. These are typically used for very expensive capital improvements such as water supply and distribution or development/ enhancement of improved access. Last, assessment districts can fund specific fuel projects that address
specific geographic regions for a specific period of time. For example, assessment districts may co-fund
utilities and water improvements.
Funding strategies should consider the total amount required, the schedule and duration of funds required, the
focus of spending – whether it is capital or maintenance-related projects – the geographic area and the project
types. Funding strategies also need to consider the effort required to obtain and administer the funds. Grants
may require matching funds in the form of hard cash or in-kind services that can range from relatively simple to complex forms and justification. The National Database of State and Local Wildfire Hazard Mitigation
Programs (www.wildfireprograms.usda.gov) presents how other communities have obtained funds and what
they have done with those funds.
Regardless of funding mechanism, several common challenges need to be considered. When raising money
for long-term projects, it is critical to build in factors for inflation and cost-escalation. Raising funds for
ongoing maintenance is more difficult than raising seed money for one-time demonstrations.
5.5 Grant Opportunities
In the past ten years, an unprecedented amount of federal and state aid has been available for fire hazard
reduction. Most federal aid is linked to proximity to federal lands, which may pose a disadvantage for the City of Palo Alto. One exception to this linkage is funding through the Department of Homeland Security.
The California FireSafe Council website hosts a “one-stop-shopping” application process where an applicant
can obtain an e-grant concept paper. However even this website does not cover all programs.
The Federal Emergency Management Agency (FEMA) has a funding program that provides assistance to fire departments through its Assistance to Firefighters Grant (AFG) and the Fire Prevention and Safety Grant
Program. AFG is limited to fire departments, while the Fire Prevention and Safety Grants are open to a wider
range of organizations. FEMA has two disaster mitigation programs: the Hazard Mitigation Grant Program ( H M G P ) a n d t h e P r e -Disaster Mitigation Program (PDM). HMGP funds are available to states after a disaster has been declared to mitigate future risk from any type of disaster. Amounts are linked to the total emergency
funds. Funds from the PDM facilitate cooperation between state and local authorities with funds awarded
competitively for both planning and project implementation activities at the state and local levels as a sub-grantee. This program addresses the more traditional agency focus of earthquakes and floods; the extent of
funding for wildfire-related projects is yet to be determined.
The State Fire Assistance includes supplemental appropriate allocation through the National Fire Plan, in
addition to a regular appropriation distributed by formula to state foresters through the USDA Forest Service. These funds can be used to plan and implement hazard mitigation projects, including fuel management,
prevention and mitigation education, and community hazard reduction. The process for obtaining funds is
competitive and available nationwide, with 35 percent distributed among the states to meet firefighting preparedness and safety needs.
Obtaining funds through grants often involve intricate application process or include administrative burdens
associated with monitoring how funds are spent and complex reporting requirements. Using funds for
ongoing projects is a concern because the sustainability of grant funding is sometimes questionable.
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Grant opportunities often become available for a short period of time. Requirements and levels of funding change annually. For example, the federal Department of Homeland Security and the Federal Emergency Management Agency recently announced a new policy for funding wildfire mitigation. On September 8,
FEMA Mitigation Chief David Maurstad issued a policy that describes how the post-disaster Hazard
Mitigation Grant Program ( H M G P ) a n d t h e P r e-Disaster Mitigation grant program (PDM) can be used for wildfire mitigation activities by eligible grant applicants.
Activities eligible for funding under these grants include creation of defensible space through removing or
reducing vegetation; the application of non-combustible building envelope assemblies, use of ignition-
resistant materials, and proper retrofit techniques for structures; and hazardous fuels reduction vegetation management or thinning within two miles of at-risk structures. Check with your state Emergency
Management Office or FEMA Regional Mitigation staff (http://www.fema.gov/about/regions/index.shtm) for
more information about HMGP and PDM grants.
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6 TREATMENT STANDARDS AND METHODS
6.1 Treatment Standards for Vegetation Types
For each vegetation type group, the resulting fuel bed characteristics after treatment are described7.
Following the vegetation prescriptions, a set of guidelines for creation and maintenance of a fire safe area (defensible space) around residences and other improvements are recommended. In all vegetation types,
preference for removal should be given to non-native invasive species.
6.1.1 Prescription for Grasslands
• Mow or graze to no longer than 4 inches in height, or disc
• Native grasses should be mowed to a height no shorter than 4 inches and may be mowed later in the
year to accommodate seed ripening and seed distribution 8
• Maintain brush cover less than 30%
o less than 20% where slope steepness is greater than 20%
o Requires annual treatment, usually requiring treatment of all grass near structures within 2
weeks of starting to mow.
• Alternatively, prescribed burn in late spring or early fall with a resulting cover of not less than 20%
6.1.2 Prescription for North Coastal Scrub and Chaparral
• Mow/grind to cut and mulch shrub tops within treatment area; alternatively,
• Create islands of less than 12 feet in diameter or 2 times the height of tallest shrub (whichever is
smaller) can remain. Clumps should be natural in appearance including specimens of variable age
classes
7 These standards/prescriptions were initially developed by Amphion, Inc. for use by the FEMA-funded East
Bay Hills Vegetation Management Consortium (VMC). These standards/prescriptions have been reviewed
and adopted by the following agencies in the consortium: Cities of Berkeley, Oakland, and Piedmont; East Bay Municipal Utility District; East Bay Regional Park District; University of California; Lawrence Berkeley
Laboratory; and PG&E. As part of the review process, a Citizen’s Advisory Committee and a Technical
Advisory Committee, which were comprised by a cross-section of members of the public, reviewed and commented on the standards. The reference is Amphion Environmental, Inc. 1995. Fire Hazard Mitigation
Program and Fuel Management Plan for the East Bay Hills, prepared for the East Bay Hills Vegetation
Management Consortium, Oakland, California.
8 Acterra is available to advise on the timing of native grass seed cycles, especially in relation to invasive
weed seed cycles.
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• Distance between islands shall be greater than 2 times the height of tallest shrub or a minimum of 8 feet, whichever is greater
• Retain between 20-30 percent of brush areas in brush crown cover
• The removal of brush should be based on criteria which are listed in approximate order of importance
to fuel management objectives:
o Relative flammability - remove the most flammable species first.
o Plant vigor - remove shrubs of low vigor, dying or dead shrubs.
o Sprouting capability - remove species with sprouting capacity first.
o Effects of plant species on soils - i.e. retain shrubs with slope-holding capacity, that increase
soil nutrients (ceanothus).
o Value for wildlife food and cover.
o Aesthetic values.
o The order of priority will change according to local conditions such as the relative abundance of each species. For example, where coffeeberry is not abundant, it may be placed high in priority to retain. Attempts should be made to maintain diversity of species.
• Maintain a crown cover of less than 30%
• Can convert to grass, especially in fuel breaks
• Maintain less than 20% dead material in the shrub canopy
• Protect oak, madrone, buckeye and trees shorter than 6 feet in height. Cut out shrubs below drip lines
and within 6 feet from edge of tree canopy
• Anticipate 3-5 year treatment cycle
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Priority For Removal Follows: Remove Only If Necessary
chamise coffeeberry
coyote bush buckeye
poison oak ceanothus
Himalaya blackberry wild currant
northern sticky monkey flower California blackberry
coastal sage brush bush lupine
scrub oak madrone
manzanita toyon
oaks
Figure 31: Initial Priority of Removal for Brush.
6.1.3 Prescription for Oak Woodlands
• Prune branches up to 3 inches in diameter for a height of 8 feet. Prune up to a maximum of 1/3 the
height of trees that are less than 24 feet tall.
• Maintain under 5 tons/acre of duff no deeper than 3 inches.
• Leave all trees bigger than 8 inches diameter. Leave 1/3 of the trees under 8 inches to retain a range
of size categories and species. Maintain a stand density of less than 50 trees per acre as long as
canopy is still closed.
• Can mulch site to a maximum depth of 2 inches to prevent invasion of noxious weeds.
o Treatment cycle is from 7-10 years.
6.1.4 Prescription for Riparian Forest
Avoid treatment. Where necessary:
• Create or maintain an 8 feet vertical clearance between live needles and understory fuel. Remove all
dead material. Prune branches up to 3 inches in diameter. Prune up to a maximum of 1/3 the height
for trees less than 24 feet in height.
• Maintain less than 10 ton/ac. Depth of duff no greater than 5 inches.
• Mulch to between 2 and 5 inches in depth.
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o Treatment cycle is between 10-15 years.
6.1.5 Defensible Space Guidelines
Palo Alto staff will be responsible for maintaining a 100 feet wide defensible space on all sides of any structure in the two parks. All dead plants and combustible materials shall be removed within 100 feet of
each structure to establish and maintain a defensible space. Removal of combustible materials includes, but is
not limited to, the following actions:
• Cut grass and weeds to less than 4 inches. Cutting of native grass and wildflowers may be delayed
until after seed set unless they form a means of rapidly spreading fire to any structures.
• Remove all dead plant material from within 100 feet of each structure. This includes keeping the ground, roofs, decking, and balconies free of dead leaves, needles or other plant debris. This also
includes removing from trees loose papery bark, and dead branches smaller than 3 inches in diameter,
to 8 feet above ground. Remove all dead branches from within live ground covers, vines, and shrubs. Refer to Figure 1 explaining pruning.
• All live vines and live branches smaller than 3 inches in diameter shall be cut up to a height of 8 feet
above ground. Figure 32 provides a description of pruning best practices.
Figure 32: Pruning Example.
Prune branches to a height of 8 feet above the ground. In young trees, prune branches on the lower one-third of the height of the tree. Do not disturb or thin the tree canopy, as this promotes growth in the understory, which is more easily ignited.
• Remove plants as necessary to break vertical continuity between ground covers, shrubs, trees, and
decks or overhangs on buildings. Vertical separation is the distance from the top of shrubs or ground cover to adjacent trees, designed to minimize the spread of fire to the crown of trees or structure
roofs. Vertical spacing should be a minimum of 8 feet or 2 times the height of the understory plants
to the leaves or needles of adjacent overstory trees, decks or overhangs, whichever provides greater
separation. For overstory trees under 24 feet in height, the minimum clearance can be reduced to 1/3
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of the overall height of the overstory tree provided this reduced clearance does not form a means of rapid transmission of fire.
• In areas without a tree overstory, create shrub islands per the standard for north coastal scrub. Within
100 feet of improvements, grass between shrub islands should be mowed when cured (dry).
• Remove all branches within 10 feet of any chimney or stovepipe including chimneys on adjacent
properties.
• Chipped materials can remain on the site provided the chipped mulch layer is no greater than 2 inches
in depth.
6.2 Description of Treatment Methods
6.2.1 Summary
Fuels can be removed on a large scale by prescribed burns, grazing animals, and mechanical treatment. In small open space areas and around structures, hand labor is effective in reducing the fuel load. Eucalyptus
tree removal may be effective in specific locations of high risk. Fuels can be redistributed on a large or small
scale through mechanical treatments, such as mowing, discing, or grading.
In all the following treatments except hand labor, economies of scale are dramatic; the larger the project, the
greater the efficiency.
6.2.2 Timing of Treatments
The timing of the initial or follow-up treatments is important to achieve the desired fuel management
performance standards and resource management objectives. Given the variable nature of fuels through changes in weather and season over time, the schedule of the treatment may often be just as important as the type of treatment selected. For example, treatments in grasslands typically take place when grass cures or
dries out. Cutting grass too early will be ineffective, as the grass will usually grow back, negating the
treatment. Conversely, cutting grass too late will leave the grass in a hazardous condition during periods of high fire danger. Fuel treatments also need to be conducted when the weather is not too dry or windy, as some
treatment types - especially mechanical treatments - may inadvertently start fires.
Timing the treatment methods appropriately can reduce potential impacts to special-status species or sensitive
wildlife species. It is likely that there will be some months of the year when particular practices need to be implemented (e.g., pre-treatment nesting surveys or avoidance of breeding habitat) to avoid adverse affects to
special-status species.
Timing treatments to either control or avoid the spread of invasive plant species or insect pests is also critical. For example, treatments performed when plants have set or are setting seed will spread the seed whether it is a
native plant or invasive weed. Treatments should therefore take advantage of differences in the timing of
seeding of native plant species and avoid periods when invasive species are in seed. Pruning of pines and
eucalyptus should be done when insect pests are not flying to minimize the associated spread and damage from these insects. Pruning should take place from November to April to minimize the susceptibility to bark
beetles or red turpentine beetles. In most cases, the timing and method of treatment can be modified to
accommodate local habitat needs and still reduce fire hazard to an acceptable level.
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6.2.3 Hand Labor
Hand labor involves pruning, cutting or removal of weeds or shrubs either by hand or with hand-held
equipment. This process is slow and expensive, but most selective and has little impact beyond the removal of the target plants. This technique generates considerable debris when pulling, pruning, and cutting
vegetation. The debris is not always removed from the site due to the high cost of doing both the clearance
and removal by hand. Not removing the debris, however, leaves a significant hazard, possibly greater than
pre-treatment because the debris may be voluminous, dry, well aerated, and quite flammable. This method is most commonly used by residents to reduce fuel volume on private lands, or by hand crews on short-term
contract with the City of Palo Alto to reduce hazard adjacent to improvements. Some expertise is required to
work with trouble species such as poison oak, to prune oaks and control shrubs, and to identify new fuel hazards as they arise. Hand labor encompasses the operations of pruning and weed-whipping, tree removal, pruning, bark pulling, removal of dead wood within the tree/shrub canopy, litter removal and mulching, and
establishing new plant material. Hand labor allows use of a wide variety of methods to reduce fuel load,
including both chemical and mechanical treatments.
Hand Labor - Pruning Trees and shrubs must be hand-pruned to vertically separate fuels. Pruning lower branches of trees is usually done with a hand-held pole saw (with or without a motorized chain saw attached).
Lower branches on shorter trees can be pruned with loppers.
Hand Labor - Weed-whipping Like mowing, weed whipping reduces fire hazard by reducing the fuel
height. However, it is done by hand to avoid harming rock outcrops and desired small plants (such as oak regeneration and landscape material). This treatment is generally limited to small material such as grass or
short herbs. Weed whipping may be accomplished any time of the year, and regardless of whether the
material has cured.
Weed whipping is performed with a hand-held, gas powered tool that cuts grasses and very thin woody material with a fast-spinning fishing-line type of cutter. Because this method is performed manually, it can be
used to selectively remove certain vegetation. Most large woody stems are not cut by the treatment, however
seedlings (such as oak seedlings) can be severely damaged. Treatments can be completed with greater care than the others (however the height to which plants are cut may be difficult to control if the operator is not experienced) and minimize soil disturbance and erosion. It is also often the only type of treatment possible on
steep slopes and in wooded areas. The average weed whipping rate is 750 square feet/hour.
The schedule for a skilled laborer should be tailored to the timing of their tasks. For example, selective weed whipping of annual grasses before they set seed while leaving native bunch grasses until after these plants set
seed can shift the proportion of vegetative cover over time to more bunch grasses. This shift in type of
grasses can shorten the length of time the landscape is prone to ignition. Similarly, thistle reproduction can be
minimized by cutting while they are growing, but before they set seed. Pruning should be done from November to April; this schedule avoids spreading destructive bark beetles and/or other pathogens.
The cost varies from $10,000 per acre to approximately $1,500 per acre, depending on the time of year, extent
of project, and level of detail required.
6.2.4 Mechanical Treatments
Mechanical treatments, including mowing, weed whipping, discing, and grading, rearrange rather than reduce the actual fuel load. Heavy machinery is usually used in flat areas where terrain and the presence of rocks or
numerous trees do not prohibit travel. This type of machinery should not be used on slopes over 30% because
of concerns for worker safety as well as erosion control and slope stability issues.
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Heavy machinery: attachments to tractors (brush hogs, flail, mowers, tiger mowers)
Roadside mowing is a prime example of the use of heavy machinery with attachments. A variety of attachments serve numerous purposes. For example, a brush hog attachment cuts and breaks brush plants off
and produces a mulch of the brush debris. Mowers that cut or flail grass and small woody plants are also
attached to tractors. Attachments (such as mowers) with articulated arms that reach as far as 20 feet away
from the tractor reduce the area over which the tracks must travel, and offer more maneuverability. These articulated arms also cut and/or break off material. Heavy machinery is a moderately fast, and a relatively
inexpensive treatment. There is little control over which plants are cut, but machines can travel around
isolated areas of concern.
Heavy machinery should not be used when the ground is soft in order to prevent ruts and bared soil. Soil
movement can be caused by all users on foot, bicycle, equestrian and vehicles (patrol vehicles and fire
apparatus). Soil movement can be ruts or minor depressions, which will lead to large ruts or voids. This
technique can be used at almost any other time of year, but is faster when done in the summer or fall when brush is brittle and grass has cured. It must not be used during times of high fire danger because the machines
can start fires. The under-carriage of the machine and attachments should be washed off after use in areas of
weed infestations.
Grading and Discing involves stripping a swath of land bare of vegetation with a tractor and blade. It is very effective in producing fire trails 8 to 12 feet across and as a maintenance tool for access routes. Generally,
grading is done mid-spring, by a contractor when there is still residual moisture in the soil, but after the threat
of spring rains has diminished9. Costs are reasonable, (from $100 to $300 per acre) and relate to the size of
the project and condition of trail surface.
However, there are several disadvantages to this treatment. By removing all competing vegetation, grading
creates an excellent establishment site for weedy species, which may be serious fire hazards. Untimely
grading, for example, in mid-summer, can help sow seeds of weedy exotics, such as yellow star thistle, mustard and Italian thistle. In addition, annual grading causes soil disturbance and alters drainage patterns. Runoff, blocked from cross-drainage by the banks on either side of a graded fire trail, is redirected down the
trail. This situation favors coyote bush and exotic grasses, leading to a shift in the grassland species
composition. Grading spoils will need to be feathered into the sides or smoothed back into grading area annually.
Discing involves cultivating or turning over the upper 10" of soil, and produces an uneven surface with a
discontinuous fuel distribution and is appropriate only if mowing or grazing is not applicable that year or in a specific location. Rate of production is quite high; normally the operator can disc land parcels of two acres or less within one day. Discing is normally performed annually once grass has cured (so the grass will not grow
back that season). A tractor with discer attachment can typically cultivate a swatch 15 feet wide in a single
pass. While this is an effective barrier to surface fire spread, it is also an ideal disturbed area with prime growing conditions for weeds and distribution of their seeds. Surface erosion can be significant in areas
prone to this process.
9 Residual soil moisture makes the soil pliable or workable, and allows the soil to compact. When
grading is performed when the soil is completely dry, the soil is very difficult to work. Pearson-Arastradero has high clay content soils and causes premature soil movement unless the contractor
supplements soil moisture with a water truck, which is an additional expense.
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6.2.5 Grazing with Sheep and Goats
This method includes the intentional use of sheep and goats to consume vegetation thus reducing the amount
or density of fuel. These types of livestock are not recommended to create a fuel break, but can be used to maintain this type of pre-suppression feature. Similarly, livestock can prevent grasslands from shrub
encroachment, and an oak woodland free of significant understory. The option is effective where the plants
are palatable to the animals selected. Control of the livestock and prevention of the impacts of overgrazing is
critical to successful use of this technique. As a fuel management technique, livestock need not graze every year.
Grazing can reduce or encourage weedy pest plants depending on the timing and intensity of grazing. A
range management plan and a grazing monitoring program needs to be established to identify the impacts and ensure that the animals are removed once fuel management goals are met. Perennial grasses may require modifications from management of annual grasses using grazing animals. Because presence of healthy
perennial grass stands has many benefits, these modifications are generally recommended. The benefits of
perennial grasses are that they cure later in the season, which limits the opportunity for ignition. Mowing typically can be scheduled over a longer time period. Rotation of grazing animals is preferred over greater
grazing pressure. Typically, perennial grasses react best when grazing is applied after seed maturation - from
late spring through the fall. Goats may import seeds from another weedy site. The herd can be quarantined at
goat herd’s ranch for three days where they will be fed alfalfa to clear out their systems. The herder can also use short-haired goats that will carry fewer seeds in their fur.
The herding instinct of sheep and goats allows professional herders to range in very mobile bands without the
installation and maintenance of permanent fences. Portable electric fences are commonly used to help control the herd and the outcome of their grazing. Goats will browse materials up to 6 feet above the ground creating
a desirable vertical separation between the canopy and ground cover. However, measures must be taken to
prevent girdling of trees by goats browsing on bark. Herd movement has the advantage of breaking off dead
material in a stand as well as punching a humus layer into the soil (if the ground is somewhat moist) and thereby removing available fuel. Grazing treatments need to be repeated, however, following up or alternating
with a different, complementary technique can extend its effectiveness.
If work is needed to be done during May-July, scheduling can present a challenge because many clients in the greater area desire the service at that time. To minimize the negative effects of grazing on a specific plant,
goats should graze after seed set of that particular plant. During initial fuel reduction treatments, goats may be
most cost-effective in the late fall or early spring when demand for their services, and possibly price are
reduced. Multi-year contracts, and contracts for larger areas typically lower the costs per acre. Providing a place where the herd can stay during the winter also lowers costs for treatment. Providing a water source for
livestock is another way to reduce costs. Water sources can be as rudimentary as a plastic wading pool or a
portable trough.
A herd of 200-300 goats can generally treat one acre per day. Costs can vary from $300 to $1000 per acre with an average of $700 per acre, depending on fencing requirements as well as type and density of vegetation
present. The cost includes transportation, the shepherd’s salary, supplements and healthcare for the goats,
fencing and insurance.
6.2.6 Broadcast Prescribed Burns
Prescribed burning reintroduces fire into the ecosystem as a "natural treatment" and can promote native flora and aid containment of fires by reducing fuel volumes.
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Prescribed burns are usually performed by the local fire protection district. CalFire may be willing to participate in a limited prescribed burning program as part of their hazard reduction efforts within the Vegetation Management Program, even though the project area would be outside the State Responsibility
Area. If burns were conducted by CalFire, the State would not only assume liability, but also share costs.
Regardless, it is likely that CalFire and other nearby fire protection districts and departments would offer mutual cooperation and/or assistance.
Several precautions, such as installing firebreaks and notifying various agencies, must be taken before
performing a prescribed burn. Treatment boundaries are often road and trail crossings, which reduces the
number of fire breaks that need to be created by fire personnel, thereby reducing labor costs and time needed to prepare for the burn as well as minimizing the amount of surface soil disturbance and potential for soil
erosion.
Prescribed burning requires the development and approval of a prescription or burn plan, which is typically developed by the local fire protection district in consideration of fuel reduction requirements, local weather
conditions, and available resources for fire management. The soot and smoke generated, as well as the chance
of escape, make prescribed burns a public safety concern. Planning and coordination with interested parties
must be an integral part of the program.
Broadcast burning may occur throughout the year; however, it is usually conducted during late spring when
the ground is still wet or during fall or winter after plants have completed their yearly growth cycle and their
moisture content has declined. Spring burns are preferred by some fire staff to ensure a greater measure of public safety, however, there may be impacts to animal and plant reproduction activities. Fall burns are more
closely aligned with the natural fire cycle found in California. If a prescribed burn were to be conducted in
the fall, the period before leaves or new herbaceous material covers the slopes will be short (possibly a month
or two).
Prescribed burning can enhance the local grasslands and promote the abundance of wildflowers. Any small
oaks or shrubs to be retained will need to be protected during the burn to prevent their mortality. While the
abundance of wildflowers the subsequent years is an appealing sight, the burned area will be temporarily blackened.
6.2.7 Eucalyptus Tree Removal
By removing eucalyptus trees their canopy no longer contributes to a fire in the form of a crown fire or ember
production. Additionally the production of surface fuels is reduced since biomass production (branches,
leaves, duff etc.) is decreased. This technique has positive impact on reducing spotting potential, heat output,
spread rate and, potentially, ignitability depending upon what replaces the overstory.
Tree removal varies from cutting of individual trees, to removal of entire overstory canopy. This process can
be slow and expensive, but can be selective with limited impact beyond the removal of the target plants
(depending upon scale of removal). Sometimes harvesting techniques can be qui t e r a p i d . I f t h e w h o l e t r e e i s not harvested, the technique generates considerable debris (from tree branches) that should be removed using machinery to haul. The boles of trees hauled away and other debris should be either hauled away or may be
burned later as a part of a prescribed burn (pile or broadcast). A portion of debris may be left as a sort of
erosion control measure and to cover bare spots.
And bats may use eucalyptus trees as perches and nesting sites. Replacement perches and nesting platforms
for raptors can be constructed, located, and installed prior to removal of the trees to minimize displacement of
raptors. If the tree harbors a maternal bat roost, removal should be coordinated with the appropriate wildlife
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agencies, including the California Department of Fish and Game and possibly the US Fish and Wildlife Service. Volunteers can locate and construct the raptor perches and nesting platforms, with guidance from suitable experts (e.g. Audubon Society or the Point Reyes Bird Observatory).
Tree removal creates patches of disturbance by the removal operation. Subsequent treatment of the area is
dependent upon the species that encroach into these patches. Removal of exotics or weed species on an annual basis should be anticipated until an acceptable stable vegetation type is re-established.
Sprout removal is often required as a follow up treatment, involving the application of herbicides and/or other
techniques such as grinding the stump or placing plastic over the stump.
6.2.8 Herbicide Application to Control Invasive Plants
Using herbicides to control invasive plant species that exacerbate wildfire risk is used as part of an Integrated Pest Management10 program and in combination with other treatment measures (e.g., mowing, burning and hand removal). Application following another treatment method in which plants are trimmed or shortened can
increase the effectiveness of the chemical treatment. Herbicides can also be used to kill herbaceous plants in
exposed areas, such as roadside grass and weeds, and are typically applied while the grasses and weeds are still actively growing. Foliar treatments are generally not applied within seven days of significant rain because
the herbicide may be washed off before it is effective, and not on windy days because of concerns for spray
drift.
The use of Garlon 4 Ultra herbicide can be used to treat areas of eucalyptus resprouting, removing the need to completely uproot or grind down the eucalyptus stump. Foliar application of Roundup to eucalyptus re-
sprouts is another typical, successful chemical treatment, and can be used to eliminate small-diameter fuels in
areas of high ignition risk. The use of a thistle-specific herbicide, Transline, is effective in controlling the spread of yellow star thistle, artichoke thistle, and bull thistle.
Herbicides do not remove any vegetation from an area’s fuel load; the dead plant matter continues to exist at
the site and could continue to be a fire hazard if not collected and disposed. Health, safety and environmental
concerns have limited the widespread use of chemicals over the past 20 years, and repeated use of chemicals is not preferred due to the prevalence of unwanted species building resistance to herbicides. Additionally,
concerns regarding water quality and other potential environmental impacts that may occur with prolonged
use of and exposure to herbicides and other chemical applications further limit their frequent or widespread use as a treatment.
Application of herbicides is typically performed by hand, and can include sponging, spraying, or dusting
chemicals onto unwanted plants. Hand application provides flexibility in application and is ideally suited for
small treatment areas. Roadside application of herbicides may employ a boom affixed to or towed behind a vehicle.
Herbicide application requires specific storage, training and licensing to ensure proper and safe use, handling,
and storage. Only personnel with the appropriate license are allowed to use chemicals to treat vegetation. Herbicide application is also only applied per a prescription prepared by a Pesticide Advisor licensed in that county. Personal protection equipment is essential to limit personnel exposure to chemicals.
10 Integrated Pest Management is a strategy that uses an array of biological, mechanical, cultural, and
hand labor, to control pests, with the use of herbicides as a least-preferred method of control.
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6.3 Best Management Practices
The protection and preservation of culturally and environmentally sensitive areas is one of the primary drivers
for development of an updated Fire Management Plan. The development of a comprehensive plan not only
protects these features from the affects of fire, but ensures that vegetation treatment, fuel management, or fire mitigation efforts are planned and executed in a manner that prevents potential additional adverse impact.
The following steps are considered best management practices for the continued protection of environmental
areas. These steps are ideally suited to on-going fire management planning and the execution of specific fire
management actions described within this plan.
• Detailed site inventory prior to treatment to determine the location of sensitive sites. Exploration into
the use of knowledgeable volunteers to conduct a more detailed, site-wide survey is warranted.
• Site planning and design to determine specific vegetation treatment actions based on fire management
benefits, environmental impact, and required mitigation activities.
• Protection during vegetation treatment using best management practices tailored to impacted sensitive resources.
• Protection of disturbed environmentally sensitive areas following either specific fire management actions.
The above vegetation treatment actions have been commonly used throughout the State of California.
Through their implementation, a series of best practices has emerged to limit their adverse impact on the
environment and to assist in the selection and planning of their application.
6.3.1 Hand Labor
D u e t o the direct relationship of personnel to the environment in which they operate, hand labor can represent an approach that provides the least adverse impact to environmentally sensitive areas. However, specific fire
management goals and the characteristics of the sensitive area or resource must be assessed to develop an
actual work plan and associated activities. The following management practices and considerations should be implemented during site planning and project execution.
• Provide or confirm adequate training, experience, and oversight to ensure that personnel are familiar
with hand labor operations and planning, site conditions, potential and identified sensitive resources, and the identification of specific environmental features or conditions that must be avoided.
• Avoid treatment actions during conditions that may affect water or run-off including during storms or
severe weather or immediately following severe weather.
• Avoid excessive foot or vehicle traffic on slopes, unimproved or non-designated trails, or outside of
preexisting roads or access points.
• Inspect areas for nesting birds to determine if activity should be postponed or adjusted by the
establishment of a buffer area.
• Clean all tools and equipment following actions and prior to movement into new environmental areas to prevent the spread of invasive or non-native plants.
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6.3.2 Mechanical Treatments
Due to the potential for large equipment use, rapid action, and large-scale area operations, mechanical
treatments can have significant adverse impacts on sensitive areas. As a result, pre-planning and site supervision are extremely important for any planned mechanical treatment actions. The following
management practices and considerations should be implemented during site planning and project execution.
• Provide or confirm adequate training, experience, and oversight to ensure that personnel are familiar with mechanical treatment operations and planning, site conditions, potential and identified sensitive
resources, and the identification of specific environmental features or conditions that must be
avoided.
• Avoid treatment actions during conditions that may affect water or run-off including during storms,
periods of precipitation, or immediately following severe weather. In addition, avoid scheduling any
treatment actions during seasons with significant predicted precipitation. Cease operations or postpone planned operations including movement of vehicles or equipment during precipitation conditions that may combine with vehicle activity to cause damage to roads, trails, or adjacent land
areas.
• Plan treatment actions and equipment selection to minimize damage or alterations to existing soils.
Determine locations of potentially erosive soils prior to treatment. Restrict operations that may
adversely affect sensitive soil systems such as serpentine soil areas, erosion prone soils, or riparian
zones. Restriction may include using road-based operations only, and avoiding riparian set-backs established by regulatory agencies.
• Maintain a buffer of 25-50 feet between operations and water bodies or designated riparian areas.
Avoid crossing drainage channels, run-off areas, or dry streambeds. Install and manage run-off barriers for rainwater in all treatment and operating areas. Restrict mechanical removal of trees to
areas further than 50 feet from drainage channels.
• Restrict vehicle traffic to preexisting roads or pre-planned access points based on equipment size and operations. Limit transport and support equipment to existing roads. Limit heavy equipment use t o
slopes less than 30%. Install erosion control measures on all vehicle roads and traffic areas.
• Maintain strict monitoring and control of fueling and maintenance operations. All maintenance
actions that may produce spills should be executed in areas with secondary containment protection,
away from any water bodies or drainage areas. Clean up of all spills should be done on-site, with
materials ready for use. Inspection of equipment for new leaks and mechanical problems should be performed daily, prior to operations.
• Inspect areas for nesting birds to determine if activity should be postponed or adjusted by the establishment of a buffer area.
• Clean equipment following actions and prior to movement into new environmental areas to prevent
the spread of invasive or non-native plants.
• Plan operations around expected seeding conditions of targeted species (either prior to or sufficiently
afterwards) to ensure efficiency of treatment action.
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• Cease actions during periods of high fire danger or during red flag conditions. Ensure that all mechanical equipment have approved spark arrestors and comply with California Public Resources
Code (PRC) sections 4431, 4435, 4442, and 4437 to limit potential for ignition of incidental fires.
• Maintain on-site fire suppression resources to include shovel, water pump, fire extinguisher, and two-way radio or communications for fire reporting.
6.3.3 Grazing with Sheep and Goats
• One of the primary adverse impacts of grazing is over-grazing and the resulting exposure of bare
ground. Over-grazing can increase the potential for soil erosion, water run-off and drainage, elimination of native plant species, and spread of non-native plants and weeds. Prepare a grazing
management plan by a certified range specialist that specifies goals, stocking levels, grazing periods,
installation of range improvements (such as water sources) to evenly distribute utilization of feed, and
monitoring and performance criteria.
• Develop a site-specific annual grazing plan that includes project-level plans for stocking, timing, and
resource management goals.
• Prior to introduction, all animals should be quarantined and fed weed-free forage to limit spread of
invasive or unwanted plant species as well as prevent spread of livestock diseases.
• Limit grazing to non-riparian areas.
6.3.4 Broadcast Prescribed Burns
Prescribed burns can have significant impacts on sensitive areas both from environmental and cultural
standpoint. The planning and execution of a prescribed burn must be carefully developed. A prescribed burn
can adversely affect the duff layer, generate large and unpredicted amounts of smoke, and transition from a
controlled event to one that is uncontrolled and dangerous.
• Provide or confirm adequate training, experience, and oversight to ensure that personnel are familiar
with broadcast prescribed burn operations and planning, site conditions, potential and identified sensitive resources, and the identification of specific environmental features or conditions that must be avoided.
• Develop a smoke management plan describing desired outcomes and specific actions for onsite personnel including a test burn, continual evaluation of smoke dispersal, monitoring of wind patterns,
and monitoring of potential visibility impacts to primary roads and highways.
• Develop public safety plans to be executed throughout the prescribed burn cycle including press and information releases, signs and notifications, patrols on roads and access points, and development of
a fire contingency plan.
• Maintain a buffer between the prescribed burn area and water bodies or drainage into riparian zones. Buffers should be a minimum of 25 feet for 5% slopes, 75 feet for 5-10% slopes, and 250 feet for
10% or greater slopes. No prescribed fires should be ignited near streams or in riparian zones.
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• Plan the prescribed burn to minimize post-fire erosion into water bodies and drainages through natural barriers, proper construction of fire lines along contours, and proper erosion control barrier
deployment. Minimize prescribed burning in areas with highly erodible soils.
• Cultural and social sites and structures shall be excluded from burn area through planning, hand-lines, or other fire protection operations. On-site personnel will be briefed on locations and features
of cultural or social sites to include incident command or response personnel. Avoid prescribed
burns in areas with utility infrastructure, existing property or structures, or archeological sites.
• Manage fuel moisture through pre-fire assessment and potential fuel modification. Prior to prescribed
burn, remove ladder fuels into the tree canopy to increase safety and reduce torching.
• Conduct prescribed burns only on designated burn days as authorized by BAAQMD.
• Inspect areas for nesting birds to determine if activity should be postponed or adjusted.
6.3.5 Herbicide Application
The application of herbicides for vegetation treatment should focus on the goal of applying the least amount
of chemical required to achieve a desired outcome, consistent with the City of Palo Alto’s Integrated Pest Management policy. Best management practices for herbicide application are centered on limiting adverse or
unintended impacts of herbicides due to run-off, wind-spread, or post-treatment exposure.
• Provide or confirm adequate training, experience, and oversight to ensure that personnel are familiar with herbicide operations and planning, site conditions, potential and identified sensitive resources,
and the identification of specific environmental features or conditions that must be avoided.
Herbicide application is only applied per a prescription prepared by a Pesticide Control Advisor licensed in that county, and applied by a licensed Pesticide Control Applicator.
• Develop public safety plans to be executed throughout the treatment cycle including press and
information releases, signs and notifications, and fencing or area restrictions.
• Develop a spill contingency plan and maintain strict monitoring and control of operations. Clean up
of all spills should be done on-site, with materials ready for use.
• Chemical treatments within habitat of California Red-legged Frog should be conducted according to
U.S. District Court injunction and order covering 66 pesticides (Oct 2006) and subsequent EPA
effects determinations.
• Clean equipment following actions and prior to movement into new environmental areas.
• Avoid treating areas adjacent to water bodies, riparian areas, and primary drainage access. Follow all herbicide labels and directions in determining applications near water resources or riparian habitats.
Limit aerial application to greater than 100 feet from water resources. Limit ground and hand
application to greater than 50 feet.
• Avoid treating areas used for livestock operations or intended as grazing areas.
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PART B – POLICY REVIEW AND SUPPLEMENTAL
RECOMMENDATIONS
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1 EVACUATION AND REFUGE
1.1 Identification and Notification
The complexity of jurisdictional boundaries and responsibilities necessitates that the City of Palo Alto
participate in 1) a standing forum that includes all stakeholders and 2) creating of coordinated, regional plans.
Emergency Public Information (EPI) is generally disseminated via broadcast radio (the Emergency Alert
System and KZSU 90.1 FM), telephone and e-mail, two-way radio contact with neighborhood leaders and
Disaster Service Workers Volunteers (via ARES/RACES ham radio and other systems), and via public address systems such as speakers on first responder vehicles.
New mass-communication systems for telephone and e-mail have recently been deployed in local
jurisdictions:
• Palo Alto: Community Alerting Notification System (CANS)
• Los Altos Hills: a similar systems to CANS
• Stanford: also CANS
• San Mateo County: a county-wide system, www.smcalert.info <http://www.smcalert.info/>
• Santa Clara County: a county-wide system is pending
These systems are currently not coordinated, An incident that starts in Palo Alto and spreads to Woodside
could cause 1) a failure to notify all involved or affected and 2) inconsistent or conflicting information. The
National Incident Management System (NIMS) provides that events where multiple jurisdictions are involved may establish a Joint Information Center (JIC) to coordinate the efforts of all Public Information Officers
(PIOs). In addition, Open Space and Park Division radios lack adequate channels (especially tactical
channels) for the growing need. This will be more crucial as affected agencies switch to digital communication systems. We recommend that a pre-plan for a Foothills JIC be created which would include
notification procedures for all potentially-involved dispatch centers, and that the Open Space and Park
Division radios be updated.
A regional evacuation plan for the Foothills should also be created: "Foothills Regional Emergency Response and Evacuation Plan (FREREP)". This plan would provide for standardized signage and evacuation route
nomenclature and protocols. The Palo Alto Police Department has developed a draft plan that could be an
initial model.
Furthermore, locked gates on evacuation routes must be properly labeled and signed and first responders (including, in some cases, authorized local residents) must have keys or other access methods. For example,
the Los Trancos Road gate to the back of Foothills Park is not labeled. In another example: A Los Trancos
Neighborhood Preparedness Coordinator could be issued a key and given an assignment to open that gate in the event of an emergency.
Existing evacuation plans should be reviewed, updated as needed, and integrated into the FREREP. For
example, the Los Trancos/Vista Verde Neighborhood evacuation plans are posted at the following location:
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http://www.vistaverdeca.org/emergency_response_info.html
The (private) Pony Tracks Ranch provides emergency vehicle egress (into Palo Alto via the "stub" of Alpine
Rd. on to Page Mill) as well as a safe refuge area:
http://www.vistaverdeca.org/about9.html
1.2 Regional Cooperation
After the tragic Oakland Hills Fire of 1991, several local jurisdictions came together to form the East Bay
Foothills Forum. The same underlying conditions and principles support the formation of a similar group in the Palo Alto area, which could perhaps be called "The Midpeninsula Foothills Emergency Forum (MFEF)".
1.3 Temporary Refuge
Places of temporary refuge are located in areas of low hazard, in places that are regularly maintained (at least
annually) in a low-fuel volume condition. Los Trampas Valley is the best example of a suitable location,
however this site may also be used as by incident management teams during longer duration fires.
To enhance the effectiveness of these temporary refuges, the park staff should perform an evacuation drill. The firefighters safety zones on Trappers Ridge are NOT temporary refuge areas for anyone but firefighters
with proper training and equipment.
There are opportunities for off-site refuge; private properties in the area could provide temporary refuge, but agreements between the City and property owners would need to be formalized.
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2 CODES AND REGULATIONS
The 2007 California Building Standards Code became effective statewide on January 1, 2008. Included in the
new code are the 2007 versions of the California Building Code (based on the 2006 International Building
Code), and California Fire Code (based on the 2006 International Fire Code). With Ordinance 4975 and
4976, the City of Palo Alto adopted these codes and local amendments to the State model codes with supportive Findings of Fact, which were filed with the State Building Standards Commission. These codes
became effective in Palo Alto on January 1, 2008. The codes are comprehensive and have included the key
elements recommended by the model codes.
2.1 Existing Codes and Ordinances
Codes related to wildland urban interface fires can be found in both the building code and fire code.
2.1.1 Fire Code
Title 15 of the Palo Alto Municipal Code adopted the California Fire Code, 2007 Edition, including
Appendices B and C, and Chapters 3, 4, 5 and 25 and Chapter 1 Appendix of the International Fire Code. Sections 15.04.520 – 15.04.587 address wildland urban interface fires.
Key components of the fire code include:
• Definition of the Wildland Urban Interface Fire Area: “…all areas west of Highway 280 and all other areas recommended as “Very High fire Hazard Severity Zone” by the director of CDF.”
(Section 15.04.520).
• Requirement for Preparation of Fire Protection Plan: Addition of section 4703.1 through 4703.4
requires a site specific wildfire risk assessment be prepared by an applicant when required by the fire
code official. (Section 15.04.530)
• Requirements for Defensible Space: Addition of section 4707.1 – 4707.2 define the requirements for
an effective defensible space within 30 feet of buildings, with an additional defensible space 100 feet
when required by fire code official due to site conditions. This section also defines corrective actions and the ability of the executive body to correct conditions and make the associated expense of such correction a lien upon the property. (Chapter 15.04.530). In addition, Section 15.04.130 adds Section
304.1.2.1 that provides authorization for the fire chief to cause removal of weed or combustible
materials.
• Access Requirements: Addition of sections 4714 through 4714.3 establishes access requirements for
all driveways and fire apparatus roads. (Section 15.04.550)
o Driveways require clearances of 12 feet wide and 13.5 feet high. The code requires turnarounds for driveways greater than 150 feet in length and turnouts and turnarounds for
those greater than 200 feet in length and 20 feet wide. It requires that vehicle speed limits be
posted on entrances to bridges, on driveways and private roads.
o Fire apparatus roads require clearances of 20 feet width and 13.5 feet height. Dead end roads
greater than 150 feet in length are required to have turnarounds.
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• In addition, Section 15.04.170 amends Section 504.4 to require that access control devices (including bars, grates, gates, electric or magnetic locks or similar devises that could inhibit rapid fire
department emergency access) be approved by the fire code official and be provided with an
approved means for deactivation or unlocking by the fire department.
• Water Supply: Addition of sections 4715 through 47159 defines water supply requirements
including water sources, hydrants, adequate water supply, obstructions, identification, testing and
maintenance, clearance of fuel and standby power. (Section 15.04.560)
• Automatic Fire Sprinklers: Addition of Sections 4716 through 467716.3 adds the requirement for
new buildings to be provided with an approved automatic fire sprinkler. Existing buildings are
required to provide an approved automatic fire sprinkler when modifications are made that increase
the building area. (Section 15.04.570)
• Requirements for Suppression and Control: Addition of Sections 4717 through 4717.3.5 add general
requirements applicable to new and existing properties to provide necessary fire protection measures. These include vegetation control, maintenance of defensible space with measures that increase the requirements of Section 4707 (Section 15.04.530). These measures address (Section 15.04.580):
o Trees: Maintain horizontal clearance of 10 feet from any structure. Pruning to remove limbs
located less than 6 feet. Regularly remove deadwood and litter from trees.
o Roadway Clearance: Clear brush or vegetative growth within 10 feet on each side of
portions of fire apparatus access roads and driveways.
o Electrical Transmission and Distribution Lines: Clearance requirements provided for the various line voltages between electrical lines and vegetation.
o Access Restrictions: Provides the authorization for the fire code official to close WUI areas
to entry (exceptions made for residents, and authorized police or fire personnel.)
• Ignition Source Control: Additions of Sections 4717.4 through 4717.4.10 provide regulations to
prevent the occurrence of wildfires. These sections address clearance from ignitions sources;
smoking; equipment generating heat, sparks or open flames; fireworks; outdoor fires, outdoor
fireplaces, permanent barbecues and grills; reckless behavior. (Section 15.04.584)
• Control of Storage: Addition of Section 4717.7 provides additional requirements for storage of
hazardous materials; liquefied petroleum gas installations; explosives and combustible materials.
(Section 15.04.585).
• Dumping: Additions of Section 4717.6 provides regulations related to dumping of waste material and
ashes or coal. (Section 15.04.586)
• Protection of Pumps and Water Storage Facilities: Addition of Section 4717.7 added regulations to
increase the reliability of water storage and pumping facilities and protect such systems from
intrusion by fire. (Section 15.04.587)
• Land Use Limitations: Addition of Section 4717.8 places limits on land use to reduce the potential
threat to life safety by requiring permits for temporary fairs, carnivals, public exhibitions and similar uses.
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• E me r g e ncy Communications: Section 15.04.190 requires, by the addition of Section 5.11.1, that new buildings or buildings expanding by more than 20%, or that change occupancy classification must
provide an approved system or equipment that will allow for adequate emergency radio coverage.
2.1.2 Building Code
Title 16 of the Palo Alto Municipal Code adopted the California Building Code, 2007 Edition. In general
these sections support the adopted Title 15 Fire Code. Key components of the building code that address wildland urban interface fire include:
• Wildland Urban Interface (WUI) Fire Area: The same definition as in Title 15 applies and amends
Section 702A of the California Building Code. (Section 16.04.140)
• Sprinkler System: Section 903.2 is amended to provide an automatic sprinkler system throughout all
buildings designated in the WUI Fire Areas (except any non-habitable structures accessory to a single
family residence that have a gross floor area of 500 square feet or less). It also includes the requirement for modifications to existing structures that expand the gross floor area as listed in the
Fire Code. (Section 16.04.150)
• Roofing Requirements: Section 1505.14 amends the roofing requirements in the WUI Fire Area. A Class A fire retardant roof covering is required where more than 50% of the total roof area is replaced
within any one year period, for new structures and in the alteration, repair or replacement of the roof
of existing structures. Roofing requirements shall also comply with Section 704A.1. (Section 16.04.170)
Chapter 7A of the California Building Code provides additional requirements for materials and construction
methods for exterior wildfire exposure. It expands the roofing and attic ventilation requirements that came into effect for new buildings applying for a building permit after December 1, 2005. This portion of the code addresses:
• Roofing assemblies, coverings, roof valleys and roof gutters.
• Attic ventilation, eave or cornice vents and eave protection.
• Exterior wall coverings, openings, vents, exterior glazing and window walls and exterior door assemblies.
• Decking, floors and underfloor protection.
• Ancillary buildings and structures.
2.2 Recommendations
There are several areas that could be expanded to further improve safety in the Palo Alto WUI Fire Area. These could be done as code revisions to further enhance the code or as guidelines that are used in
enforcement of existing codes. Other best practice measures may be incorporated into City contracts and used
in public education:
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• Expand Section 15.04.520, the Area Defined as Wildland Urban Interface (WUI) Fire Area, to include the lands between Foothill Expressway / Junipero Serra Boulevard and Highway 280.
• Expand Section 15.04.530 General Requirements for WUI Fire Areas (4703.1 Fire Protection Plan Preparation) to require that Fire Protection Planning begin early in the planning/ permitting process so the location of access roads, driveways and structures can be influenced to increase fire safety and
emergency response. Require the plan to also address implementation and funding of defensible
space vegetation management (especially important for commonly held private open space).
• Expand Section 15.04.540 Defensible Space (4707.1 General Item 5.) to include all ground, decking
and balconies in addition to the specified “maintain roof of a structure free of leaves, needles or other dead vegetative growth.”
• Expand Section 15.04.550 Access Requirements (4714.2 Driveways and 4714.3 Fire Apparatus
Roads) to add standards related to gradient and horizontal and vertical curvature, bridge load limits, parking restrictions during high fire danger weather and requirements for emergency vehicle access.
• Expand Section 15.04.580 General Requirements for WUI Fire Areas (section 4717.2 Vegetation Control) to provide additional guidance for Maintenance of Defensible Space (see following guidelines).
• Expand Section 15.04.584 Ignition Source Control (section 4717.4.7 Outdoor Fires) to identify that
abatement by burning is unlawful unless by permit and unless all other applicable permits are obtained from appropriate governing jurisdictions. Burn permits are only issued to working
agricultural properties.
• Fencing: Add a section requiring fences be constructed of either noncombustible material or of timbers with a minimum of one-inch nominal thickness. For example a typical fencing might consist
of open wire mesh with four-inch posts and stringers that have a minimum one-inch nominal
thickness. Fences should be designed with removal panels or gates so during a wildfire they do not convey fire to adjacent structures.
• Signage: Add a section requiring street, road and building address signs to have a minimum letter
height of 4 inches, be 1/2 inches thick, reflectorized, painted a color contrasting with the background color of the sign, mounted on non-combustible poles and visible within 100 feet traveling from both
directions.
• Mechanical Equipment Ignition Prevention: Requirements should be included in all City contracts for construction or maintenance work in the WUI Fire Area that address ignition prevention such as
equipment (spark arrestor, overheating protection etc.), refueling, clearance of work area, cessation of
work during periods of high fire danger weather and requirements for fire suppression equipment. This is becoming more critical for new diesel-powered vehicles because clean air/emission require exhaust particulate burning systems can more easily start fires if the vehicles are taken off-road.
• Smoking: More stringent rules regarding smoking in Pearson-Arastradero Park are recommended. Restrictions should be similar to those in place at Foothills Park.
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2.3 Exterior Hazard Abatement
The following information is provided as a set of guidelines that can be developed into educational material to
facilitate compliance with existing codes. The code currently addresses treatments for exterior hazard
abatement in a general way; this section provides more specificity regarding the spacing of vegetative fuels.
2.3.1 For parcels of land one acre or less maintain parcel in complete
abatement.
• For a distance of 30 feet a structure on slope steepness less than 30 percent grade, or 70 feet on slopes greater than 30 percent grade, from all property boundaries cut dry grass and non-woody vegetation
to less than 3 inches yearly, no later than June 1.
o This may require re-mowing if late season rains promote grass growth after the first cutting.
o With prior approval of the Fire Department cutting of native grass and wildflowers may be delayed until after seed set provided they do not form a means of rapidly transmitting fire to
any structures.
• Leaves and humus may not exceed two inches in depth anywhere in a landscaped area; however, bare
earth should not be exposed in over 50% of the site and no one bare patch should be larger than 15
square feet.
• All dead vegetation (i.e. dry grass, leaves and humus) must be removed under trees and within
shrubs, vines and semi-woody plants every year by June 1.
• Dead branches must be removed from mature trees and all vines, to 8 feet above ground.
Figure 33: Pruning Example.
Prune branches to a height of 8 feet above the ground. In young trees, prune branches on the lower one-third of the height of the tree. Do not disturb or thin the tree canopy. This promotes growth in the understory, which is more easily ignited.
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• Limbs of trees and large-form shrubs that are smaller than three inches in diameter shall be pruned to provide clearance of three times the height of the understory plant material or 8 feet, whichever is
higher. Trees shorter than 24 feet in height shall be pruned of the lower one-third branches (Figure
33).
• The vertical distance between the ground and the lowest tree branches should be 3 times the height of
any shrubs planted beneath the trees or 6 feet whichever is higher. Plants under trees should
generally be shorter than 18 inches in height. Taller shrubs, including vines, semi-woody species and all chaparral species, may be near (six horizontal feet from tree crown) but not under trees.
• Remove all dead trees deemed a fire hazard by the Fire Department.
• Individual plants or shrub masses will be separated so that groupings/shrub masses will be no wider
than two times the grouping height, or 120 square feet in area. Distinct groupings of shrubs (which
includes vines, semi-woody species, all types of brush, and all chaparral species) will be designed to
dampen the spread of fire. Alternatively, shrubs can be cut and maintained to a height of two feet.
*
Figure 34: Shrub Spacing.
Design groups of plants small enough to provide horizontal separation between groups. This
allows proper maintenance and helps slow the spread of fire. Each shrub or group of plants should measure no wider than two times its height, or less than 120 sq.ft. (or 6 ft x 20 ft). The space between groups should be greater than three times the height of the shrubs, or at least a
12 ft. distance
• A vertical clearance of 5 feet shall be maintained between roof surface and portions of trees or other vegetation overhanging any building or structure.
• Wood piles must be enclosed in a non-combustible storage unit.
2.3.2 For parcels larger than one acre in size
• Maintain the area (space) within 100 feet of any structure on the parcel per the specific requirements for lots less than one acre in size.
• Maintain the area (space) within 100 – 250 feet from any structure on the parcel per the following
specific requirements:
o Shrub masses will be separated so that groupings will be no wider than two times the
grouping height, or 120 square feet in area. Distinct groupings of shrubs (which include
vines, semi-woody species, all types of brush, and all chaparral species) will be designed to dampen the spread of fire. Alternatively, shrubs can be cut and maintained to a height of two feet.
o All dead vegetation (i.e. dry grass, leaves and humus) must be removed under trees and
within shrubs, vines and semi-woody plants every year by June 1.
o Dead branches must be removed from mature trees and all vines, to 8 feet above ground.
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o Trees, and large tree-form shrubs, shall be pruned to provide clearance of three times the height of the understory plant material or 8 feet, whichever is higher. Limbs that are smaller than three inches in diameter are to be pruned up to eight feet off the ground, and in trees
shorter than 18 feet, the lower one-third of the height of the tree. See Figure 33.
o The vertical distance between the ground and the lowest tree branches should be 3 times the height of any shrubs planted beneath the trees or 6 feet whichever is higher. Plants under
trees should generally be shorter than 18 inches in height. Taller shrubs, including vines,
semi-woody species and all chaparral species, may be near (six horizontal feet from tree
crown) but not under trees.
• If a structure is within 100 feet of property boundary on adjacent lot, provide 30-foot firebreaks
following as closely as possible to the property line and along one side of all fence lines. Fire breaks are a continuous strip of ground that is mowed to three-inch height, or disced, or dozed.
• Remove all dead trees deemed a fire hazard by the Fire Department.
• Trees on the top of ridges shall be maintained to limit torching, through pruning to provide clearance of three times the height of the understory plant material or 8 feet, whichever is higher. Limbs that
are smaller than three inches in diameter are to be pruned up to eight feet off the ground, and in trees
shorter than 18 feet, the lower one-third of the height of the tree as in Figure 33.
• Within 15-feet of all public or private roadways or driveways, all grass must be mowed, disced or
sprayed to 3 inches height.
• In grasslands, 30-foot firebreaks and crossbreaks that divide the parcel into approximately 5-acre
sections. Firebreaks and crossbreaks are a continuous strip of ground that is mowed to three-inch
height, or disced, or dozed, following as closely as possible to the property line and along one side of all fence lines, ditches, and on top of all ridges. When terrain is too steep or rugged for a tractor, a hand-mowed firebreak may be required.
• Active Pastureland: 15-foot wide firebreaks and crossbreaks are required if a sufficient number of animals are present to steadily reduce height of grass during the summer months to 3 inches or less
by the end of August. If not active, 30-foot width is required.
• Active Cropland: 15-foot wide firebreaks and crossbreaks required if crop is to be harvested by mid-June. If later, 30-foot width is required.
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3 FIRE PROTECTION – STATION 8
The following is a description, appraisal and recommendation regarding staffing of, equipment for and other
response resources related to Station 8 in Foothills Park.
Figure 35: Fire Protection Resources.
3.1 Description
Fire Station number 8 of the Palo Alto Fire Department is located at 3300 Page Mill Road in Palo Alto, CA. It is a seasonal fire station that is only staffed during the daylight hours. This amounts to 12 hours per day. The
period of time it is staffed is usually from July 1st to November 1st of each year. This is essentially the fire
season for the area being protected and involves about 120 days of coverage. Whenever there is a declared
high fire danger day or the burn index indicates an ignition threat the station may be staffed beyond the 12-hour period and outside of the fire season when appropriate.
The staffing of the station currently includes 1 Captain, 1 Apparatus Operator/Engineer and 1 Firefighter.
These positions are filled through overtime allocations rather than being post positions. Initially a fire response unit located at Foothill Park was staffed with only 2 persons. It was upgraded to 3 persons following the Arastradero Fire of 1985 in the lower foothills to be consistent with contemporary fire staffing practices
and when Station #8 was constructed.
Station 8
8
Mutual Aid Stations
Plus: CalFire Saratoga Gap
Station at Skyline and Big Basin Way
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The apparatus that responds from this station is a Type III Engine Company. This is an apparatus that is primarily designed to respond to wildland fires instead of structure fires. This is similar to the types of companies used by major wildland agencies.
The station provides an initial attack capability to an area that involves about 25 square miles of urban-
wildland interface area. There are approximately 150 dwellings in the area, but that is not the primary risk. The fire history of this specific area is relatively free of major events in the past decades. The last reported
major fire in the vicinity of the upper foothills was in 1912. Significant fires in the lower foothills (primarily
light fuels) occurred in 1985, 1992, 2000 and 2007.
However, that one factor creates an impact upon existing fuel loads. The lack of major fires in the past has resulted in fuel densities that may be ready to support a wide area fire. It has been estimated that the medium
and high density fuels are about three times their normal density.
The secondary response units into this area are deployed from the “El Monte” fire station of Santa Clara County Fire located to the north and the Palo Alto Stations #2 and #5. The County Fire Station is equipped
with Type I and Type IV engines. Currently there is no direct link to this station in the dispatching of
equipment. Depending upon who reports an emergency in the area the call could go directly to the City of
Palo Alto or it could be routed through the Santa Clara County Communication Center and Palo Alto would then be notified.
The standard response into this area varies upon the level of dispatch. On medium or high dispatch days the
Palo Alto Fire Department responds Engine 8 to reports of wildland fires and supports it with another Type III (3 personnel) that is cross staffed by the truck company from Station #6 on the Stanford Campus, one Type I
from Station #2 (3 personnel), 2 Type IV cross-staffed patrol units from Stations #2 and #6 (6 personnel), one
Paramedic ambulance from Station #2 (2 personnel) and one Battalion Chief from Station #6.
Furthermore, the dispatch system provides a brush unit from the Santa Clara County El Monte Fire Station in Los Altos Hills at Foothill Community College (4 personnel from 1000-1900 hours) and can respond an
additional 4 Type I’s (12 personnel) and 3 Type IV Brush units (9 personnel). Lastly, the system has the depth
to provide additional resources from other mutual aid entities in the same area (e.g. Cal Fire Ranger Unit resources located in Cupertino and San Martin). These include additional Type III units (3 or more), air assets, hand crew resources, bulldozers and command staff to complete an overhead requirement in the event
of a major fire. Other Type 1, Type III and Type IV resources may be made available through the Santa Clara
County Mutual Aid System.
The City of Palo Alto does currently not have an adopted Standards of Cover document, but operates with an
informal response goal of 5 to 6 minutes for attendance of at least 90% of its calls for service. The department
also provides paramedic (advanced life support – ALS) response to the basic built out portion of the city
within 8 minutes for at least 90% of those types of calls (these response goal benchmarks are exclusive of the foothills area). Station 8 has not normally been considered an ALS resource. In the past 2 years a priority has
been established to staff Engine 8 with an ALS resource whenever possible.
The staffing for the station is provided in the overtime budget. Last year the amount set aside to provide coverage was $200,000.
3.2 Appraisal
The primary purpose of placing a wildland unit into this area is to prevent any ignitions from spreading beyond a reasonable fire perimeter before an adequate full fire alarm assignment and an effective response
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force can be placed on the scene. The first 10 minutes of a wildland fire are critical to restricting the size of the ultimate fire. Depending upon the fuel type and density, the slope and aspect and the effects of wind upon a flame front, the period of time that it takes to get initial control of an incipient fire is very important. This is
especially true in light fuels, when a fuel is running uphill and/or when fire conditions that consist of high
temperatures, low humidity and wind conditions exist. The fire behavior assessment of the Foothills Area indicates a high potential for fast-moving fires.
The secondary purpose of having the unit in place is to establish a point of control for the development of an
incident command system in place to address the escalation of the fire, if it is not controlled in the first 10
minutes.
The first purpose addresses the need for “distribution”. In the language of response coverage the distribution
of resources is the placement of companies, based upon risk factors to be readily available to handle the first
few minutes of fire or emergency control.
The second purpose addresses the need for “concentration”. This terminology is used to describe the
deployment of an adequate amount of resources to deal with the ultimate size of the fire. These two concepts
are inter-related in that fires that are controlled early do not need as many resources to be eventually
deployed. Therefore, early intervention is a form of cost avoidance.
This is the basic operating assumption of all seasonal fire resources. Major wildland agencies such as Cal-
Fire, the U.S. Forest Service and other wildland agencies use the concept of seasonal and part time staffing
configurations to minimize fire size to as small an area as possible.
3.3 Recommendation
The staffing of this station by utilization of overtime fire personnel is a reasonable method of addressing the
risk and hazards in the area. It is a cost effective way of reducing the impact of potential wildland fires in the study area. The elimination of this company places the responsibility for initial attack upon fire companies
that are more remote and therefore are more likely to have lengthy response times into the area.
The staffing pattern of 3 fire fighters is the minimum for the safe and effective operation of an initial attack unit for a wildland fire. This station and its current staffing configuration should be retained in the future. In addition, staffing a police officer and maintaining a ranger staff presence in the Foothills Area during high fire
risk days should be considered. This type of personnel offers extra fire detection capability and is available to
assist with evacuation should an incident require that particular action.
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4 TRAIL PLAN UPDATE
4.1 Pearson-Arastradero Preserve Trails Management Plan (March
2001)
The Trails Master Plan for Pearson-Arastradero Preserve recognizes that the preserve is located in the
Hazardous Fire Area (Section 3.3). The plan identifies management objectives, strategies and recommended
actions to meet Fire Department objectives. It recognizes the need to coordinate with the Fire Department to develop and implement a fire suppression plan that will maximize the safety of the users and the adjacent
properties, without adversely impacting the natural environment. It includes fire prevention methods for
firelines on the perimeter, as well as fuel reduction zones to compartmentalize the preserve for fire
suppression in the event of a fire.
4.1.1 Recommended Revisions
Since the Trails Master Plan was adopted in 2001, there have been new facilities developed at the Gateway Interpretive Center and a new access to Foothills Park. Fuel management recommendations take into account
these new facilities, as well as recommend the following additions and modifications to the 2001 Trails Plan:
• Addition of fuel management along the evacuation route (Arastradero Road) and management of defensible space around the Gateway Interpretive Center, parking lot and staging area to include
projects A.E1 and A.D1, A.D2, A.D3 and A.D4.
• Addition of fuel reduction zones within the interior of the preserve along existing trails for
containment including projects A.C9, A.C10, A.C11 and A.C12.
• The Master Plan identifies an option for the Fire Department to use controlled burns as a part of their wildland fire prevention plan. Two potential areas are recommended: Juan Bautista Prescribed Fire
North (A.Rx1) and Acorn Trail Prescribed Fire South (A.Rx2).
• Modify firebreak width and performance standards.
• Addition of roadside treatment standards to Clearing and Brushing for those trails that also serve as
emergency vehicle access for clearances of 13.5 feet vertical clearance and 10 feet horizontal
clearance.
• Addition to Regulatory, Warning and Educational Signs regarding fire hazard signs, education
information on fuel management and prescribe fire.
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Figure 36: Emergency/Maintenance Access Points.
Map depicts the emergency/maintenance access points of entry, trail travel routes to be maintained for use by the
Fire Department and Utilities Department when servicing the Preserve. This map also shows disc lines and indicates those sensitive resource areas in the Preserve that should not be accessed by heavy vehicles. The map has been modified to incorporate the new facilities and associated modifications to fire control treatment areas.
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4.1.2 Existing Fire Mitigation and Fuel Management in the Arastradero
Trails Management Plan
Hazardous Fire Area: The Preserve is identified in the Hazardous Fire Area. (Section 3.3)
Utilities: Access for maintenance and repair of existing utilities facilities is by all-weather surface roads that
can accommodate heavy vehicles for repairs. Primary entrance is Gate B. Clearance of fuels for 10’ radius around poles having operable devises. Tree trimming is generally done every 2 to 3 years with ground
clearing done annually. (Section 3.4)
Management Objectives, Strategies and Recommended Actions. Objective is to coordinate with Fire
Department to develop and implement a fire suppression plan that will maximize the safety of the users and the adjacent properties, without adversely affecting the natural environment (Section 4.5 and Map 4):
• Access: Provide adequate access for Type 3 and 4 vehicles.
• Fire Prevention Techniques: Use least environmentally intrusive prevention methods
• Firebreak and Control Strategies: Prevent fires from spreading on adjacent properties as well as coming into the preserve. Firebreaks/disc lines should be implemented only where they serve their intended function in fire prevention and suppression.
• Temporary Closures: Provide an option for park staff to close the Preserve when conditions such as high fire danger could pose a threat to the public.
Access (Section 4.5 pg 4-9 and Section 7-2 pp 7-7-7-9).
• Provide a 40 to 45 foot “drive” between Arastradero Road and Access Gates A and B to provide a safe place for Fire Department staff to safely park their Type 3 and 4 vehicles when opening the
Preserve entry gates.
o Ensure that all six access points can accommodate fire vehicles at all times. These access
points include:
The parking lot
The access gate on Arastradero Road adjacent to the west of the parking lot
Gate A (access limited to the existing turn-around on the west side of the first concrete bridge spanning Arastradero Creek)
Gate B, which serves as the primary Utilities Department access
Gate C, which is located off John Marthens Lane
Gate D - Vista Hill Gate in Foothills Park (one-way uphill, except in emergency situations)
o Close, restore and annually mow designated emergency access routes within the Preserve as
needed to create a circulation route for Type 3 and 4 vehicles in the case of emergency.
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• Provide emergency turn-around capability where access roads dead-end (hammer-head configuration needed for vehicle turn-around).
o To minimize potential impacts to the natural resources, these designated vehicle 'turn-
arounds' will be the only acceptable turning points for motor vehicles within the Preserve. The final siting of new 'turn-arounds' (#2, 5 and 9) should be flagged prior to construction
and the Open Space and Parks Division Manager should be advised of pending construction.
Each turn-around should be clearly delineated and mapped to prevent removal of or impact
to sensitive biological resources. Refer to Table 9 – Vehicle Turn-around Design Summary.
o Recognizing that these turn-arounds are to be used for routine maintenance, construction and
patrol. In special circumstances where larger fire trucks and over sized utility vehicles must
access the Preserve, these vehicles may not be able to use the turn-arounds and will have to travel through the Preserve in a one way direction. In this case, it is recommended that the vehicles enter and leave through Gates B and D. In the case of a wildfire, public safety will
override resource protection. In this case, the Fire Department may be required to override
these vehicle guidelines to be able to suppress a fire.
Refer to Map 36 Fire Protection & Emergency & Maintenance Access for:
• Emergency/maintenance access points of entry.
• Trail travel routes to be maintained for use by the Fire Department and Utilities Department when
servicing the Preserve.
• Disc lines.
• Sensitive resource areas in the Preserve that should not be accessed by heavy vehicles.
• Use a uniform maintenance gate at all major entry points with a universal locking device to facilitate routine and emergency access into the Preserve by multiple department staff.
Fire prevention methods (Section 4.5 pg 4-9 and Section 7.5 Vegetation Management pg 7-39)
• Fire prevention methods to be used at the Preserve include:
o Establishing fire lines on the perimeters of open space lands, leaving the interior areas in
their natural condition. These cover many of the recommended containment projects
including: A.C1, A.C2, A.C3, A.C4, A.C5, A.C6, A.C7 and A.C8.
o Posting signs indicating the severity of the fire danger (low, moderate, high, very high, and
extreme) during the fire season.
o Posting signs “No Fireworks” June 20 to July 10.
o Use herbicides as approved by the Open Space and Parks Division Manager, where appropriate in implementing the wildland fire prevention plan.
Refer to Map 4 Fire Protection & Emergency Access of the Trail Master Plan for disc lines and areas that are
to be mowed annually to maintain emergency vehicle access through the Preserve. This map also indicates those sensitive resource areas in the Preserve that should not be accessed by heavy vehicles.
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Firebreak and Control (Section 4.5 pg 4-10 and Section 7.5 Vegetation Management pg 7-39)
• Firebreaks should be disced 24 feet wide or 1 ½ times the fuel height adjacent to the road, structures
and where they can compartmentalize an area to reduce the risk of a fire igniting and/or spreading.
• Firebreaks should be eliminated where they are not providing any benefit to fire prevention or suppression.
• Ideally discing should be performed twice a year, first in late spring and then when the disc lines
have “cured.”
• If new activities/developments occur inside or adjacent to the Preserve perimeters, then the location
of the disc lines should be reevaluated and expanded as appropriate.
In addition, though not currently used, maintain an option for the Fire Department to perform controlled burns in the future as part of their overall fire prevention plan.
Temporary Closures (Section 4.5 pg 4-10) of the Trail Master Plan
The City Fire Department in consultation with Open Space staff may close the Preserve when there is a threat to public safety. When such emergencies occur, the Fire Department is to notify the Police Department and
the Open Space and Parks Division staff of emergency closures so they can notify the public. Emergency
closures may occur when:
• Weather conditions create a critical fire danger;
• Arsonists are known to be present in the area;
• Staff resources have been pulled away for other emergencies; and/or
• Other threats to public safety are present or suspected.
High Maintenance Trails - Clearing and Brushing (Section 6.2 Trails Maintenance System & Section 7.5 Vegetation Management)
The trail clearing limits for down logs and tree limbing should be 10 feet high and 3 feet wide on each side of
the trail. (Refer to Section 7, Figure 16 of the Trail Master Plan for trail clearing and brushing limits). Trail brushing limits for shrubby and herbaceous plant species extending into the trail should be 10 feet high and 3
feet wide on each side of the trail. These plants should be cleared to ground level. Clearing widths should be
directed to providing clear passage and providing an average sight line of 100-feet. Low growing and slow
growing shrubs and ground cover less than two feet in height should be left undisturbed.
Specific Trail Recommendations for Trails (Section 6.4)
• Acorn Trail - Segment 1 (Ac1): Maintain existing vehicle turn-around at booster pump station. Refer to Map 4 of the Trail Master Plan- Fire Protection & Emergency & Maintenance Access - Turn-around Point 3.
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• Arastradero Creek Trail - Segment 2 (ArC2): Providing a new vehicle turn-around in a hammerhead configuration near intersection of former Acorn Trail (now Route F) to accommodate Type 3 and 4
emergency fire vehicles. The turn-around area should be defined using the following: grading a level
area and landscaping. Such vegetation should consist of native species, similar to nearby, existing vegetation and should be placed in a natural configuration to prevent the vegetation from creating an
unsafe condition or adverse visual impact. The final siting of the turn-around should be completed
under the advisement of the Open Space and Parks Division Manager. Refer to Map 4 of the Trail
Master Plan - Fire Protection & Emergency & Maintenance Access – Turn-around Point 5.
• Arastradero Creek Trail - Segment 3 (ArC3): Locate an emergency/maintenance vehicle turn-around
in a hammerhead configuration at the existing gate on the east side of the trail. Move the gate back to
accommodate Type 3 and 4 emergency fire vehicles. Improvements to the turn-around area should be confined to the existing, flat graded pad. Minimize annual pruning to area necessary to provide for
vehicle access. Refer to Map 4 of the Trail Master Plan- Fire Protection & Emergency &
Maintenance Access - Turn-around Point 6.
• Corte Madera Trail - Segment 2(CM2): Mow the area at junction with Bay View Trail to provide
room for Type 3 and 4 emergency vehicles to perform a hammerhead vehicle turn-around following
procedures outlined in Section 7.2. Maintain a minimum cover of 2 inches to minimize potential erosion impacts. Refer to Figure 36 Fire Protection & Emergency & Maintenance Access - Turn-
around Point 4.
• Gateway Trail - Segment 1 (Ga1): Providing a 40 to 45 foot “driveway” between Arastradero Road and Access Gate A to allow a safe pull out for maintenance and emergency vehicles accessing the
Preserve11. Design of maintenance drive must take into account the existing 10-foot wide crossing
over a concrete culvert. The culvert is located approximately 28 feet from the edge of pavement.
• Juan Bautista de Anza National Historic Trail - Segment 2 (JB2): Develop turn-around in a
hammerhead configuration to accommodate Type 3 and 4 emergency fire vehicles. Locate on west
side of bridge in the area that is nearly flat and already contains hardened surfaces and non-native grassland. Avoid nearby riparian habitat and serpentine soils. Refer to Map 36 Fire Protection &
Emergency & Maintenance Access - Turn-around Point 2.
• Juan Bautista de Anza National Historic Trail - Segment 4 (JB4): Mow an area near the junction of the Portola Pastures Trail to provide room for Type 3 and 4 emergency fire vehicles to turn-around
following procedures outlined in Section 7.2. Maintain a minimum cover of 2 inches to minimize
potential erosion impacts. Refer to Figure 36 Fire Protection & Emergency & Maintenance Access - Turn-around Point 10.
• Juan Bautista de Anza National Historic Trail - Segment 5 (JB5): Developing an emergency Type 3
and 4 vehicle hammerhead turn-around at the junction with Segment 4 of the Juan Bautista de Anza Trail. Improvements to the area should be confined, to the greatest extend possible, to the existing
graded area at the trail junction. Refer to Map 4 - Fire Protection & Emergency & Maintenance
Access – Turn-around Point 9.
11 Like many of the recommendations, this has already been accomplished.
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• Juan Bautista de Anza National Historic Trail - Segment 5 (JB5): Providing a 40 to 45 foot “driveway” between Arastradero Road and Access Gate B to allow a safe pull out for maintenance
and emergency vehicles accessing the Preserve.
• Stanford Pastures Trail (SP): One year after the trail tread has been established mow an area near the boundary of the Preserve to provide room for Type 3 and 4 emergency fire vehicles to turn-around
following procedures outlined in section 7.2. Maintain a minimum cover of 2 inches to minimize
potential erosion impacts. Refer to Map 33 Fire Protection & Emergency & Maintenance Access - Turn-around Point 1.
• Meadowlark Trail (MeL1): Develop a hammerhead vehicle turn-around for Type 3 and 4 emergency
vehicles to turn-around near the old barn site. Improvements to the turn-around should be confined to the existing graded pad that formerly served as the driveway for the old barn. Refer to Map 33 Fire
Protection & Emergency & Maintenance Access – Turn-around Point 7.
• Woodland Trail Segment 1(Wo1): Maintain existing, paved vehicular turn-around that encircles the water tank for utility vehicles. Note that this turn-around is not suitable for Type 3 and 4 fire vehicles
due to the tight turning radius around the tank. Refer to Map 4 - Fire Protection & Emergency &
Maintenance Access – Turn-around Point 8.
4.1.3 Vegetation Management
4.1.3.1 Brushing and Clearing Defined
Brushing and clearing constitutes the removal of vegetative materials as required to provide adequate vertical and horizontal clearance for safe passage along a trail.
4.1.3.2 Techniques for Maintaining a Clear Passageway
Vegetation on the south sides of the trail should be pruned to allow passage, but should be preserved, as much
as possible, to protect the aesthetic quality of the trail. Typically, vegetation is cleared to a height of 10 feet and 2 to 3 feet to either side of the trail edge to accommodate equestrian use. A minimum sight distance of
100 feet should be maintained, where feasible to facilitate safe shared use of the trail system.
Good pruning practices should be followed, including cutting branches almost flush with the limb, and cutting stumps at ground level or below. Large limbs should be pruned almost flush with the trunk. Dead and dying limbs and snags, which may fall on the trail, should be removed. Typically, ground cover plants and low
shrubs should not be removed except on the actual trail tread.
Where specific trail segments (Refer to Section 6) recommend controlling invasive, non-native plants, the Arastradero Preserve Management Plan management strategies should be used. This means that vegetation
management adjacent to the trails should be performed in a way that maximizes the safety of the users and
minimizes adverse environmental impacts. Appropriate management techniques include in order of preference, control with “beneficial insects”, where they have been determined through study not to have detrimental environmental impacts, removal by hand pulling, or pruning with weed whips or (as a last choice)
with chemicals. When weed whips are employed, a 2-inch minimum cover should be retained to minimize
exposure of bare earth and resulting impacts from splash erosion and gullying. Herbicides should only be used as approved by the Open Space and Parks Division Manager. In addition, the chemicals must be applied
in accordance with California State law and must adhere to the conditions set forth in the City’s “Integrated
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 108
Pest Management Plan” to ensure the safety of staff, visitors and wildlife and to reduce or eliminate the possibility of chemicals entering the creek.
Where a trail is located on a side slope, the vegetation on the uphill side will be more intrusive and should be
cut back more severely than on the downhill side.
Low growing vegetation should be allowed to return to cut slopes to increase soil stability. Replant areas with vegetation indigenous to those areas or compatible with plantings already in place.
Overhanging limbs should be cut back flush with the tree trunk, brush should be grubbed out and disposed of
out of sight of the trail and scattered not stacked. Excess rock should be disposed of in the same manner as
brush and limbs. All loose roots protruding over one inch above the trail tread should be cut out to at least 4 inches beyond the margins of the tread and to a depth of 4 inches below tread level and removed. Holes
resulting from root removal should be filled and compacted with mineral soil and or rock, not exceeding 2
inches in diameter.
Advance warning of all vegetation management activities in the Preserve shall be given to the Open Space
and Parks Division Manager at least one week in advance of the work.
Turn-around Existing Conditions Recommended Actions
#1
Trail: SP
Mowed grassland dominated by non-native
plants
Mow area near boundary of the Preserve for Type 3 & 4 emergency fire vehicles to turn-around. Maintain 2” min. grass
cover.
#2
Trail:JB2
Area is nearly flat &
already contains hardened surfaces and non-native
grassland
Perform minor grading to develop hammerhead turn-around for
Type 3 & 4 emergency fire vehicles on west side of bridge in the area that is nearly flat. Avoid nearby riparian habitat and
serpentine soils.
#3
Trail: Jct. ArC
& Ac
Existing hardened surface
adjacent to lake & utility booster station.
Maintain the existing vehicle turn-around at booster pump
station. No grading or vegetation removal required.
#4
Trail: CM2
Mowed grassland
dominated by non-native plants
Mow area at junction of Bay View Trail for Type 3 & 4
emergency fire vehicles to turn-around. Maintain 2” min. grass cover.
#5
Trail:ArC2
Grassland dominated by
non-native plants on opposite side of utility road
from creek & does not
affect creek zone
Perform minor grading to develop hammerhead turnaround in
area that is nearly flat near junction of Route F (now scheduled for closure) for Type 3 & 4 emergency fire vehicles. Define area
with native vegetation in a natural configuration. Avoid nearby
riparian habitat.
#6
Trail: ArC3
Existing dirt driveway. No
grading or vegetation removal required
Locate at existing gate on the east side of the trail. Move gate
back to accommodate Type 3 & 4 emergency fire vehicles. Confine turn-around area to existing graded pad. Minimize
annual pruning to area necessary for vehicle access.
#7 Existing drive to old barn site. No grading or Confine turn-around to existing graded pad that formerly served
City of Palo Alto Foothills Fire Management Plan Update
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Trail: MeL1 vegetation removal req. as the driveway for the old barn.
#8
Trail: Wo1
Existing road around the water tank. Tight radius
will not accommodate Type 3 & 4 vehicles
Maintain existing, paved vehicular turn-around that encircles water tank for utility vehicles.
#9
Trail: Jct. JB 4 & 5
Flat grassland area at junction of two trails.
Minor grading may be
necessary
Perform minor grading to develop hammerhead turnaround at the junction Juan Bautista de Anza Trail Segs. 4 & 5. Confined work
(to the greatest extend possible) to existing graded area at the trail
junction.
#10
Trail: JB 4
Mowed grassland Mow an area near junction with Portola Pastures Trail to provide room for Type 3 & 4 emergency fire vehicles to turn-around.
Maintain 2” min. grass cover.
Figure 37: Vehicle Turn-around Design Summary.
Final siting of all turn–around to be approved by Open Space and Parks Division Manager prior to initiating any grading.
4.2 Foothills Park Trails Maintenance Plan (January 29, 2002)
The Trails Master Plan for Foothills Park recognizes that the preserve is located in the Hazardous Fire Area
(HFA) and Mutual Threat Zone (MTZ). The plan identifies the existing fuel break system but focuses on maintenance of the existing trails.
4.2.1 Recommended Revisions
The following are recommended additions and modifications to the 2002 Trails Maintenance Plan:
• Addition of fuel management along the additional evacuation routes to northwest (Interpretive Center to The 600-700 block of Los Trancos Road), northeast (Boronda Lake to Alexis Drive), and from Towle Campground along Wildhorse Valley to Las Trampas Valley.
• Addition of four Firefighter Safety Zones along Trappers Ridge Trail at Los Trancos Trail, Madrone Fire Road and two highpoints (high point and south end); projects # F.F1, through F.F4.
• Addition of annual maintenance of defensible space around the Interpretive Center, parking lot and
staging area, campgrounds, pumping stations to include projects F.D1 through F.D8.
• Addition of annual maintenance ignition reduction projects at picnic sites and campgrounds to
include projects F.I1 through F.I7.
• Addition of fuel reduction zones along existing trails for containment including projects F.C1
(Trappers Trail), F.C2 (Pony Tracks south of Trappers Ridge), F.C3 (Pony Tracks north of Trappers
Ridge), F.C4 (Bobcat Point) and F.C5 (north of entry gate).
• Modify tables for managing trails within specific vegetation types to accommodate fuel modification
performance standards for the containment projects.
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• Addition to Regulatory, Warning and Educational Signs regarding fire hazard signs, education information on fuel management and prescribed fire.
4.2.2 Existing Fire Mitigation and Fuel Management in the Foothills Park
Trails Maintenance Plan
Staff Responsibilities (Executive Summary, page 104)
The foothills parks are staffed by rangers that are based out of the Foothills Park office. Park rangers are
responsible for patrolling, monitoring and maintaining Foothills Park. They oversee the fieldwork of the
California Conservation Corps (CCC) work program, as well as other volunteer work programs at the Park. Rangers also lead guided nature walks and give nature slide shows. In addition, while the primary
responsibility for fire and medical emergencies lies with the City Fire Department, rangers will typically be
the first response team for fire and medical emergencies within the park.
Park Maintenance/Utility/Emergency (e.g. fire) (Section 2.4 pg 2-5)
There are three other entry points off Page Mill Road that maintenance and emergency vehicles use to provide
access from Page Mill Road. These are labeled as Gates 2, 3 and 4. Gate 2 provides access to the Charlie
Brown firebreak and Toyon Trail. Gate 3 provides access to the Park Reservoir, a 1.5 million gallon city water reservoir. Gate 4 provides access to the Trapper’s Fire Trail and to the southern portion of the Los
Trancos Trail. In addition, utility vehicles and park maintenance/patrol vehicles wanting to access the
Arastradero Creek Trail (Segment 3) within Arastradero Preserve enter Foothills Park and access this trail
from Gate D. Gate D is located on the one-way road that leads from the Interpretive Center to Vista Hill in Foothills Park. There is also an access easement from Los Trancos Road in Portola Valley connecting to the
service yard at the north end of the park. This easement is only accessible by park staff.
Hazardous Fire Area (Section 2.4 pg 2-6): The Park is identified in the Hazardous Fire Area because of the tremendous vegetation fuel load and the potential for extended response times in the event of a fire due to
limited access/egress into the park. The area has also been designated as a Mutual Threat Zone (MTZ) by
agreement with the California Department of Forestry and Fire Protection. This means that a fire within the
City’s jurisdiction is a threat to the State’s jurisdiction and vice versa.
Firebreaks (Section 2.4 page 2-6 – 2-8): To meet the City’s objective of “reducing government costs and
citizen losses from wildland fire by increasing initial attack success and or protecting assets at risk through focused prefire management objectives” a fuel break system has been designed and implemented for Foothills Park. The main firebreak (by distance and location) is the Trapper’s Firebreak Trail. It is two miles long,
essentially running along the spine of the park. There are also several smaller breaks that are maintained as
access roads for fire response. These branching firebreaks, which are located throughout the park, and the
Trappers Firebreak Trail, are graded and compacted to a width of 10 feet or greater to accommodate the City Fire Department’s Type 3 and 4 vehicles. These firebreak trails have the potential to be reduced in width, or
substituted with shaded fuel breaks if environmentally desirable. (A shaded fuel break allows annual grasses
to return to the land, but not medium or heavy fuels.)
Evacuation (Section 2.4 Page 2–8): In addition to the firebreak trail network, “safety islands” have been
identified in the park and an evacuation plan has been developed for the park. The primary evacuation route
(as identified in the Palo Alto Comprehensive Plan) is Page Mill Road. The main road through the park
connects to an access easement that provides an alternate evacuation route between Page Mill Road and Los Trancos Road.
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Natural Resources Management Objectives Adjacent to the Trail (Section 3.4 pg 304). Retaining native vegetation except in areas where City personnel determine that plants are creating a fire or safety hazard, or where vegetation is located within the tread of routinely maintained roads, trails and designated firebreaks
Noxious Plants and Pathogens (Page 4-17 – 4-24): Control and prevention of non-native invasive plant
species is recognized as quite important. Infestations of non-native invasive plant species have been found to alter ecosystem functions such as nutrient cycles, hydrology, and wildfire frequency. Non-native invasive
plant species pose a complex problem, but the management of the spread is a key factor in preventing long-
lasting and negative effects on the native ecosystem. The plan recognizes that trail maintenance activities need
to address the fact that most of these species gain a foothold by invading soil that has been disturbed, such as through re-grading or vegetation clearing that results in the removal of ground cover plants adjacent to the
trail tread. The plan includes a table of the non-native invasive plants of greatest ecological concern. (Table
4-6 page 4-18 – 4-24.)
Sudden Oak Death (SOD) (page 4-24 – 4-25): Sudden Oak Death is caused by the pathogen Phytophthora
ramorum that kills oaks and several other California woodland species found in Foothills Park. The pathogen
appears to kill trees and shrubs swiftly and has greatly affected the visual integrity and diversity of the
California Oak woodland as it is defined today. First discovered in California on Tan Oaks in 1995, it has
now been confirmed in ten California counties, including Santa Clara County. Note: Information available on this SOD has expanded since the maintenance plan was developed in 2002.
Trails Maintenance Program Development (Section 5.2 pg 5-2): Trail inspections are integral to all trail
maintenance operations. Inspections should occur on a regularly scheduled basis, the frequency of which will depend on the amount of trail use, the location, age, and the types of structures and the types of soil/terrain. At
a minimum, all trail and trail structures/features should be inspected at least once a year at the close of the
winter “wet season”. All trail inspections should be documented in writing in a field log. Conditions that
have the potential to be the most hazardous to the public, which should be watched for during field inspections, include:
• Heavy fuel loads which could create a high or critical danger fire hazard in the park.
Other Staff Duties Related to Park Protection & Trail Activities (Section 5.3 pg 5-9): While the primary responsibility for fire and medical emergencies lies with the City Fire Department, Park Rangers will typically
be the first response team for fire and medical emergencies within the Park. Foothills Park Rangers have
received various limited levels of fire fighting training and are dispatched as a resource to fires and other emergency calls. They are a valuable resource as they provide enhanced local knowledge of the area, and can
be used to augment Engine Eight or to perform other tasks, such as evacuation or reconnaissance. The Palo
Alto Fire Department has rated the Rangers control of public areas and Park maintenance practices, which
augment the City’s fuel management system as outstanding (Palo Alto Draft Fire Management Plan, April 1997).
Trail Maintenance Guidelines (Section 6 pages 6-1 – 6-81): Section 6.3 provides an overview in table format
of the existing trail characteristics (Table 6-1 page 6-4 through 6-8). The tables currently do not include information regarding whether the trail segments are a part of the firebreak system.
Section 6.5 (pages 6-10 through 6-21) includes management strategies for maintaining hiking trails. A series
of tables provides a summary of managing trails within grasslands/ oak savanna (Table 6-2), chaparral (Table
6-3), mixed woodlands (Table 6-4) and bay woodlands (Table 6-5). These tables include treatments of the vegetation ground plan, middle plane and overhead canopy. They do not specifically address management
practices to be used if the trail is a part of a fire containment area. Section 6-8 includes Vegetation
City of Palo Alto Foothills Fire Management Plan Update
Draft (15 January 2009) 112
Management Recommendations text that expands upon the summary tables with additional descriptions and standards (pages 6-56 – 6-63).
Trail Communication Tools (Section 6.11 pg 6-77 through 6-81): Trail signs include temporary/ permanent
closures for hazards associated with critical fire danger (page 6-80). Interpretive trail guides and programs
offer the opportunity to educate visitors about the biological diversity of Foothills Park and the importance of staying on trails to avoid damaging this unique resource (page 6-81).
City of Palo Alto Foothills Fire Management Plan Update
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5 REFERENCES
Acterra - Action for a sustainable earth, www.acterra.org, 3291 East Bayshore Rd., Palo Alto, CA 94303,
meetings September 2008.
Anderson, H.E. 1983. Aids to determining fuel models for estimating fire behavior. USDA Forest Service
General Technical Report. INT-122.
California Department of Parks and Recreation, Initial Study Mitigated Negative Declaration – Andrew
Molera State Park / Pt Sur State Historic Park Water System Improvements, April 2006.
California Native Plant Society, Inventory of Rare and Endangered Plants of California, August 2001
City of Palo Alto, Final Arastradero Preserve Trails Management Program, 2001
City of Palo Alto, Final Foothills Park Preserve Trails Management Program, 2002
City of Palo Alto, Geospatial Information System Data, provided May 2008
Environmental Protection Agency, Frogs and Pesticide Hazards, December 2006
Finney, M.A. 2006. An overview of FlamMap modeling capabilities. USDA Forest Service Proceedings.
RMRS-P-41. 213p.
Grijalva, Ruben, Fire Chief, Martin, Bruce, Project Manager, Palo Alto Fire Department, Palo Alto Foothills Fire Management Plan, April 1997
Ministry of Water, land, and Air Protection, British Columbia, Environmental Best Management Practices for
Urban and Rural Land Development, June 2004
Natural Diversity Database, California Department of Fish and Game, Special Vascular Plants, Bryophytes, and Lichens List, July 2008
Natural Diversity Database, California Department of Fish and Game, Endangered, Threatened and Rare
Plants List, July 2008
Natural Diversity Database, California Department of Fish and Game, Special Animals List, Feb 2008
Natural Diversity Database, California Department of Fish and Game, Endangered and Threatened Animals
List, May 2008
Rothermel, Richard. 1983. How to Predict the Spread and Intensity of Forest and Range Fires, USDA Forest Service Intermountain Forest and Range Experiment Station, General Technical Report INT-143.
Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. U.S.
General Soil Map (STATSGO2) for California.
United States Geological Survey, United States Department of Interior. The National Map LANDFIRE: LANDFIRE National Existing Vegetation Type (2006 September – 2008, May).
City of Palo Alto
Department of Planning and Community Environment
California Environmental Quality Act
DRAFT MITIGATED NEGATIVE DECLARATION
I. DESCRIPTION OF PROJECT
Date: February 9, 2009
Project Name: Foothills Fire Management Plan Update
Project Location: The project area is located in the most southern region of the City of Palo Alto,
in the northern part of Santa Clara County, west of U.S. Highway 280. The
project area includes the two parks in the foothills of Palo Alto: Foothills Park
and Pearson Arastradero Preserve. In addition, the project includes segments
of Skyline Boulevard, Page Mill, Arastradero, and Los Trancos Road.
Applicant: City of Palo Alto
Department of Planning and Community Environment
Clare Campbell, Planner
Owner: City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Project Description:
The proposed 2009 update to Palo Alto Fire Management Plan proposes fuel management on approximately 330
acres of Foothills and Arastradero Parks to protect lives, enhance the safety of improvements in and around the
parks and to enhance the natural resource ecosystem health. Fuel management fall into the following categories:
roadside treatments along potential evacuation corridors, creation and maintenance of firefighter safety zones,
creation and maintenance of defensible space around structures in the parks, ignition prevention, and treatments to
aid containment of fires in and within the park.
II. DETERMINATION
In accordance with the City of Palo Alto’s procedures for compliance with the California
Environmental Quality Act (CEQA), the City has conducted an Initial Study to determine
whether the proposed project could have a significant effect on the environment. On the
basis of that study, the City makes the following determination:
The proposed project COULD NOT have a significant effect on the
environment, and a NEGATIVE DECLARATION is hereby adopted.
X Although the project, as proposed, could have a significant effect on the
environment, there will not be a significant effect on the environment in this
case because mitigation measures have been added to the project and,
therefore, a MITIGATED NEGATIVE DECLARATION is hereby adopted.
Page 1 of 4
The attached initial study incorporates all relevant information regarding the potential
environmental effects of the project and confirms the determination that an EIR is not required
for the project.
In addition, the following mitigation measures have been incorporated into the project:
BIO - 1: A qualified biologist or park staff trained to do so by a qualified biologist shall conduct a tail-gate
training session to all relevant personnel who will be performing treatments regarding protected species and habitats
in the project area, the limitations on areas that can be accessed on foot or with equipment, and the legal
consequences of take of protected species or habitat. The training shall be repeated for new personnel coming to the
project site. Dogs shall be prohibited from the project site.
BIO - 2: Vegetation removal in any vegetation type from February 15 to August 31 shall require a survey
for nesting birds by a qualified biologist or by park staff trained to do so by a qualified biologist and avoiding
removal of nests in active use. If raptor nests are detected, a buffer area will need to be established around the nest
in consultation with the California Department of Fish and Game. The buffer may be 250 feet.
BIO - 3: Vegetation removal in areas of serpentine soil, oak woodland, chaparral, coastal scrub and riparian
forest habitats shall require a survey for rare plant species by a qualified biologist/ botanist prior to vegetation
removal. Known rare plant locations should be treated in a way that benefits the rare species. This may include
limiting the area of treatment in order to provide a buffer around the plant(s), or may include selectively trimming
competitive vegetation adjacent to the plant(s). Some species may benefit from disturbance; the specific actions to
be taken should be determined in consultation with a botanist. The plant survey shall be performed during the bloom
period. After surveys in the same locations over three separate years, subsequent surveys are not necessary in that
area unless there a newly listed plant species could occur in the habitat. This should be determined by consulting the
California Department of Fish and Game.
BIO - 4: Vegetation removal, including dead and downed debris, shall require a survey for presence of San
Francisco dusky-footed woodrat by a qualified biologist or by park staff trained to identify woodrat houses by a
qualified biologist. If woodrat houses are found, disturbance should be avoided and a minimum five-foot buffer
should be provided around the house. If, for public safety reasons, it is necessary to move the house, the process
must be coordinated with the California Department of Fish and Game. All relevant workers shall receive
instruction regarding woodrat houses prior to their start of work.
BIO - 5: Prior to the removal of any tree that is 12 inches or more in diameter breast height, a survey for
perennial bat roosts and, during the breeding season from February 15 to August 31, raptor nests shall be conducted
by a qualified biologist or park staff trained by a qualified biologist to identify these resources is required. If
present, removal cannot continue without CDFG guidance.
BIO - 6: Discing within 500 feet of a lake, pond or creek, shall require a biological survey to determine
impacts to California red-legged frog, California tiger salamander, San Francisco garter snake and Western pond
turtle and whether permits are required from the USFWS/CDFG.
BIO - 7: Discing in grassland shall require a pre-construction survey for American badger, California red-
legged frog and burrowing owl by a qualified biologist.
BIO - 8: Trimming of coast live oaks shall follow the City’s Tree Ordinance (Title 8). Coast live oak or
Valley oaks that are 11.5 inches in diameter or more measured at 54 inches above grade may not be removed
without a permit, and may not be pruned such that more than 25 percent of the crown is removed or the tree is left
unbalanced.
BIO - 9: Wetlands mapped in Pearson Arastradero Preserve shall be avoided when weed-whipping or
mowing. Modify the Fire Management Plan Best Management Practice that requires that a grazing plan be prepared
to include protection of drainages and wetlands from the impacts of grazing animals.
BIO - 10: For treatments in Foothills Park or on Page Mill Road along the Park border, a pre-work survey
for stands of locally important plants shall be conducted, and the plants avoided as long as it does not impair public
safety. Field crews shall be educated about the sensitivity of these plant species. For additional information, see
Table 3 in Appendix A of the Biological Assessment (Source Reference #5).
BIO - 11: For proposed treatments, clean all tools and equipment following actions and prior to movement
into new environmental areas to prevent the spread of invasive or non-native plants.
BIO - 12: Measures shall be taken to clean equipment, tires, and shoes to prevent the spread of Sudden Oak
Death, and that any materials infected with the disease be disposed of in accordance with State or County
Agricultural Commission guidelines. To reduce the possibility of spreading the disease, it is recommended that
Page 2 of 4
work not be done in wet or muddy conditions, and that infested areas be avoided to the extent feasible. Additional
guidelines are available from the County Agricultural Commissioner.
BIO - 13: A qualified biologist shall be present onsite to monitor all treatment work. The biological monitor
shall have the authority to stop work if deemed necessary to protect state or federally protected species, and shall
work directly with the City staff. Prior to the start of work each day, the monitor shall thoroughly inspect the
treatment area and adjacent habitat areas to determine if any protected species are present in the area and shall
remain onsite through out the day while work activities are occurring. If a protected species is encountered, the
onsite biological monitor shall determine whether treatment activities are remote enough from the animal that it will
not be harmed or harassed.
BIO - 14: Treatment equipment and materials shall be staged in an already disturbed area such as improved
trails or existing roads.
BIO - 15: Prior to introduction, all grazing animals shall be quarantined for three days and fed weed-free
forage to limit spread of invasive or unwanted plant species, as well as prevent spread of livestock diseases.
BIO - 16: Grazing shall be limited to non-riparian areas.
BIO - 17: Maintain a buffer between the prescribed burn area and water bodies or drainage into riparian
zones. Buffers should be a minimum of 25 feet for 5% slopes, 75 feet for 5-10% slopes, and 250 feet for 10% or
greater slopes. No prescribed fires shall be ignited near streams or in riparian zones.
BIO - 18: Herbicide treatments within habitat of California Red-legged Frog shall be conducted according to
U.S. District Court injunction and order covering 66 pesticides (Oct 2006) and subsequent EPA effects
determinations.
BIO - 19: Avoid herbicide treatments in areas adjacent to water bodies, riparian areas, and primary drainage
access. Follow all herbicide labels and directions in determining applications near water resources or riparian
habitats. Limit aerial application to greater than 100 feet from water resources. Limit ground and hand application
to greater than 50 feet.
Geology - 1: The City shall conduct treatment actions in a manner that avoids erosion and adverse affects on
sensitive soil systems by avoiding treatment in sensitive soils and potentially erosive soil areas. This mitigation
measure shall be implemented through development of a study that identifies all potentially erosive soils prior to
beginning treatment actions and development of an erosion control plan subject to review and approval of City Staff
that restricts treatment operations that may adversely affect the sensitive soil systems.
Geology - 2: Avoid treatment actions during periods of precipitation, or immediately following severe weather.
Geology - 3: (Hand Labor) Avoid excessive foot or vehicle traffic on slopes, unimproved or non-designated
trails, or outside of preexisting roads or access points.
Geology - 4: (Mechanical). In addition to avoiding treatment actions during periods of precipitation, or
immediately following severe weather, avoid scheduling any treatment actions during seasons with significant
predicted precipitation. Cease operations or postpone planned operations including movement of vehicles or
equipment during precipitation conditions that may combine with vehicle activity to cause damage to roads, trails, or
adjacent land areas.
Geology - 5: (Mechanical) Plan treatment actions and equipment selection to minimize damage or alterations to
existing soils.
Geology - 6: (Mechanical) Maintain a buffer of 25-50 feet between operations and water bodies or designated
riparian areas. Avoid crossing drainage channels, run-off areas, or dry streambeds. Install and manage run-off
barriers for rainwater in all treatment and operating areas. Restrict mechanical removal of trees to areas further than
50 feet from drainage channels.
Geology - 7: (Mechanical) Restrict vehicle traffic to preexisting roads or pre-planned access points based on
equipment size and operations. Limit transport and support equipment to existing roads. Limit heavy equipment use
to slopes less than 30%. Install erosion control measures on all vehicle roads and traffic areas.
Geology - 8: (Grazing) The City shall conduct grazing operations in a manner that avoids over-grazing and
prevents erosion by appropriately limiting the intensity and scope of grazing. This mitigation measure shall be
implemented through development of a grazing management plan prepared by a certified range specialist that
specifies goals, stocking levels, grazing periods, installation of range improvements (such as water sources) to
evenly distribute utilization of feed, and monitoring and performance criteria to address the potential erosion
conditions created by over-grazing.
Geology - 9: (Grazing) Develop a site-specific annual grazing plan to be approved by a certified range specialist
that includes project-level plans for sticking, timing, and resource management goals.
Page 3 of 4
Geology -10: (Burns) The City shall conduct prescribed burns in a manner that minimizes post-fire erosion into
water bodies and drainage through the use of natural barriers, fire lines along contours, erosion control barrier
deployment, and avoidance of areas with highly erodible soils. This mitigation measure shall be implemented
through development, prior to conducting a prescribed burn, of a prescribed burn erosion control plan (or included in
the prescribed bum plan) subject to review and approval by City Staff.
Hazards -1: All treatment methods involving fueling and maintenance operations shall be strictly monitored
and controlled. This mitigation measure shall be implemented by conducting all maintenance actions that may
produce spills should be executed in areas with secondary containment protection, away from any water bodies or
drainage areas; cleaning up all spills shall be done on-site, and clean-up materials shall be maintained on site so they
are readily available for use. Inspection of equipment for new leaks and mechanical problems should be performed
daily, prior to operations.
Hazards -2: Cease actions during periods of high fire danger or during red flag conditions. Ensure that all
mechanical equipment have approved spark arrestors and comply with California Public Resources Code (PRC)
sections 4431, 4435, 4442, and 4437 to limit potential for ignition of incidental fires.
Hazards -3: Maintain on-site fire suppression resources to include shovel, water pump, fire extinguisher, and
two-way radio or communications for fire reporting.
Herbicide Application
Hazards -4: The City shall conduct herbicide application in a manner that uses the least amount of chemical
required to achieve a desired outcome; the herbicide treatment shall be consistent with the City of Palo Alto's
Integrated Pest Management policy.
Hazards -5: Provide or confnm adequate training, experience, and oversight to ensure that personnel are
familiar with herbicide operations and planning, site conditions, potential and identified sensitive resources, and the
identification of specific environmental features or conditions that must be avoided. Herbicide application shall only
be applied per a prescription prepared by a Pesticide Control Advisor licensed in Santa Clara County, and applied by
a licensed Pesticide Control Applicator.
Hazards -6: The City shall conduct herbicide application in a manner that protects public safety by informing
the public of treatment and restricting access, when deemed appropriate. This mitigation measure shall be
implemented through development of a public safety plan, which shall include requirements for press and
information releases, signs and notifications, and guidelines for fencing or area restrictions, and shall be subject to
review and approval of the Pesticide Control Advisor and the Directors of Community Services and Fire
Department, and the terms of which shall be executed throughout the treatment cycle ..
Hazards -7: The City shall conduct herbicide application in a manner that protects against and minimizes
damage from spills by maintaining strict monitoring and control of operations, and providing for clean up of all
spills to be done on-site, with clean-up materials readily available for use. This mitigation measure shall be
implemented through development of a spill contingency plan subject to review and approval of the Pesticide
Control Advisor and the Directors of Community Services and Fire Department.
Hazards -8: Chemical treatments within habitat of California Red-legged Frog shall be conducted according to
U.s. District Court injunction and order covering 66 pesticides (Oct' 2006) and subsequent EPA effects
determinations.
Hazards -9: Clean equipment following actions and prior to movement into new environmental areas.
Hazards -10: Avoid treating areas adjacent to water bodies, riparian areas, and primary drainage access. Follow
all herbicide labels and directions in determining applications near water resources or riparian habitats. Limit aerial
application to greater than 100 feet from water resources. Limit ground and hand application to greater than 50 feet.
Hazards -11: A void treating areas used for livestock operations or intended as grazing areas.
~ 02.~O~m ~ner Date
Page 4 of4
ENVIRONMENTAL CHECKLIST FORM
City of Palo Alto
Department of Planning and Community Environment
PROJECT DESCRIPTION
1. PROJECT TITLE
Foothills Fire Management Plan Update
2. LEAD AGENCY NAME AND ADDRESS
City of Palo Alto
Department of Planning and Community Environment
250 Hamilton Ave.
Palo Alto, CA 94303
3. CONTACT PERSON AND PHONE NUMBER
Clare Campbell, Planner
City of Palo Alto
650-617-3191
4. PROJECT SPONSOR’S NAME AND ADDRESS
City Manager’s Office
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94303
Contact: Kenneth Dueker
5. APPLICATION NUMBER
Not Applicable
6. PROJECT LOCATION
The project area is located in the most southern region of the City of Palo Alto, in the northern
part of Santa Clara County, west of U.S. Highway 280. The project area includes the two parks
in the foothills of Palo Alto: Foothills Park and Pearson Arastradero Preserve. In addition, the
project includes segments of Skyline Boulevard, Page Mill, Arastradero, and Los Trancos Road.
Foothills Fire Management Plan Update Page 1 of 46 Mitigated Negative Declaration
Figure 1: City of Palo Alto
Pearson Arastradero Preserve
Foothills Park
Foothills Fire Management Plan Update Page 2 of 46 Mitigated Negative Declaration
Figure 2: Foothills Park
Foothills Fire Management Plan Update Page 3 of 46 Mitigated Negative Declaration
Figure 3: Pearson Arastradero Preserve
Foothills Fire Management Plan Update Page 4 of 46 Mitigated Negative Declaration
7. COMPREHENSIVE PLAN DESIGNATION
The project area, Foothills Park and Pearson Arastradero Preserve, is comprised of three land use
designations that are described in the Palo Alto 1998 – 2010 Comprehensive Plan. There are no
proposed changes in the use; the existing park use is an appropriate use for these land use
designations.
Foothills Park is designated as Public Park. This land use provides for open lands whose primary
purpose is active recreation and whose character is essentially urban. These areas have been
planted with non-indigenous landscaping and require a concerted effort to maintain recreational
facilities and landscaping.
Pearson Arastradero Preserve is designated as Publicly Owned Conservation Land and
Streamside Open Space. The Publicly Owned Conservation Land designation provides for open
lands whose primary purpose is the preservation and enhancement of the natural state of the land
and its plants and animals. Only compatible resource management, recreation, and educational
activities are allowed. The Streamside Open Space designation describes the corridor of riparian
vegetation along a natural stream. Hiking, biking, and riding trails may be developed in the
streamside open space. The corridor will generally vary in width up to 200 feet either side of the
center line of the creek.
8. ZONING
The project area, Foothills Park and Pearson Arastradero Preserve, has the base zoning of Public
Facility (PF). In addition to this base zoning, Pearson Arastradero has an added zoning overlay
of Site and Design (D) that requires proposed development projects to undergo a more critical
design review. The PF zone district is designed to accommodate governmental, public utility,
educational, and community service or recreational facilities. There are no proposed changes in
the use; the existing park use is an allowable use in this zone district.
9. PROJECT DESCRIPTION
The City of Palo Alto developed a Fire Management Plan in 1982. The 1982 Plan provided the
planning framework for fire control activities for the City and the Palo Alto foothills area. The
goal of the 1982 Plan was “to reduce government costs and citizen losses from wildland fire by
increasing initial attack success and/or protecting assets at risk through focused pre-fire
management activities.” In 1997, the City of Palo Alto staff developed a draft update to the 1982
Plan. Although the draft update was not formally adopted by the City Council, it provided an
updated framework and interim objectives for fire management within the foothills area. The
City of Palo Alto initiated an update process for the Foothills Fire Management Plan (Plan) that
involved a combination of City staff personnel from a wide cross section of city operations,
stakeholders from across the Palo Alto area, and members of the Palo Alto community.
The Palo Alto Foothills consist of a mix of urban, semi-urban and open space lands on the
eastern slope of the Santa Cruz Mountains. Within the city limits of Palo Alto, the Palo Alto
Foothills area west of the Foothills Expressway and Junipero Serra Boulevard represents a
Wildland Urban Interface area (WUI). The City’s Fire Department’s response area in the WUI
Foothills Fire Management Plan Update Page 5 of 46 Mitigated Negative Declaration
covers nearly 10 square miles, from Skyline Boulevard in the Palo Alto foothills to Foothill
Boulevard and from Page Mill Road to Los Trancos Road. Approximately 200 residences and
large business complexes (many of them exceeding a million square feet in area) are located in
Palo Alto’s WUI. The City’s Emergency Operations Plan (June 2007) notes that 11 health care
facilities, 10 schools and 25 government-owned buildings are located in the wildland urban
interface threat areas, along with 19 miles of roadway that are subject to high, very high or
extreme wild fire threat. The Plan addresses fire hazard protection within Foothills Park and
Pearson Arastradero Preserve, which represent the majority of the Wildland Urban Interface fire
area, as well as the major evacuation routes in proximity to these parks.
The proposed 2009 update to Palo Alto Fire Management Plan (Plan) proposes fuel management
on approximately 330 acres of Foothills and Arastradero Parks to protect lives, enhance the
safety of improvements in and around the parks and to enhance the natural resource ecosystem
health. Fuel management fall into the following categories: roadside treatments along potential
evacuation corridors, creation and maintenance of firefighter safety zones, creation and
maintenance of defensible space around structures in the parks, ignition prevention and
treatments to aid containment of fires in and within the park.
Fuel management is justified by various objectives, spanning the need to keep fires from
crossing boundaries, minimizing damage to developed areas and minimizing damage to natural
resources. Other fuel management complies with regulations, which themselves are intended to
increase access, or facilitate fire suppression. A variety of fuel management practices reduce the
chance of damage to life and property. There are techniques that keep fire from crossing
boundaries, which could be in the form of fuel management to compartmentalize the landscape,
or fuel management along the borders of the parks, or modification of the volume or structure of
the fuels to reduce chance of ember production or enhance firefighting effectiveness.
The proposed Plan also addresses several issues aside from the proposed fuel management
strategies for the Foothills. These other components are contained in a section of the Plan that
includes recommendations related to administration of the Plan, including consistency between
the Foothills Park Trails Maintenance Plan and the Pearson Arastradero Trails Management
Plan, review of Municipal Ordinances, review of staffing of Fire Station 8, suggested
implementation plan, and identification of potential funding . Those policy recommendations are
purely administrative and do not amount to activities for which it is foreseeable that a direct or
indirect change in the physical environment would result. Therefore, the environmental impacts
that are discussed in this checklist refer specifically to the components of the Plan that address
physical changes to the project area as a result of the proposed fuel management strategies for
the Palo Alto Foothills.
Fuel Management
Not every area identified as a potential fire hazard can be modified to produce low-intensity
fires. Not only would this be too costly, but environmental impacts would also be unacceptable.
Fires that burn in un-treated areas will not benefit from treatment elsewhere. The exception is
that the fire may be contained in the treated area, thereby never reaching the untreated area.
Foothills Fire Management Plan Update Page 6 of 46 Mitigated Negative Declaration
Identifying Potential Treatment Areas
Selection of pre-fire fuel treatment areas is based on the probability of the event and the potential
damage of that event. Factors taken into consideration are:
• Need for enhanced access and egress: Actions to promote life safety and efficient
emergency response is of utmost importance. Roadside treatments that aid safer access and
evacuation have a high likelihood and magnitude of benefit.
• Ignition locations: Treatments are located either where ignitions are likely to occur or could
spread into (e.g. a grassy spot near a road, or near a barbeque). Even where an area would
burn with great ferocity, if there is only a remote chance of ignition, it has a lower treatment
priority.
• Adjacency to improvements or other sensitive values at risk from wildfire: The closer
the fuel source is to a structure, heavily used area, or environmentally sensitive area, the
higher the treatment priority. Therefore, an area in the interior of a Park/Preserve, well
removed from other vulnerabilities, should not be treated with the same priority as a
hazardous situation near valuable and/or vulnerable resources.
• Propensity of the treatment to aid containment: Treatments that facilitate access or create
locations where containment is likely to be successful have greater benefit because they
improve fire suppression success. Also, a fire that is easy to contain will be more likely to
have fewer environmental impacts from the suppression action itself.
In the end, the most intense fire, and possibly the largest potential fire size, may not be highest
on the treatment priority list. This may be because the likelihood of the event coupled with the
potential damage from the fire would not yield the highest risk.
Current Fuel Management Program
The two parks have a long history of managing vegetation to both promote fire safety and to
enhance natural resources. In some cases, projects attain both goals. Previous projects in
Foothills Park encompass discing along park boundaries, grazing with goats in Las Trampas
Valley, maintenance of a mowed fuel break along various locations, including a broad fuel break
sometimes 200-ft wide along Trappers Ridge, and more narrow fuel breaks along the Madrone
Fire Road, Shotgun Fire Road, Pony Tracks Fire Road, and around Fire Station 8. Fuel
management in Pearson Arastradero includes discing along park boundaries, mowing 14
different broad areas within the park, and maintenance of vegetation along park roads.
Grading of the fire roads has been a component of the contract between Van der Steen General
Engineering and Palo Alto for annual firebreak maintenance. Grading has been performed as part
of this contract only in the last three years; low annual rainfall and erosion has not warranted
grading. To minimize grading work, city employees from all departments are strictly prohibited
from driving the bare soil roadways that do not have asphalt or compacted rock. Grading, as a
component of the contract, is specified as only when necessary.
Foothills Fire Management Plan Update Page 7 of 46 Mitigated Negative Declaration
Discing has been performed by City staff for the last 7+ years. After trials with several methods,
the City found that a two discing cycles work best. The first cycle is performed when the threat
of spring rains has diminished, drainages or low areas are dry, and annual grasses are still green.
The depth of discing is less than 6-inches, and causes a disruption of the growth of the annual
grasses (less biomass). The second cycle of discing is after the annual grasses have cured/dried
but there is still some soil moisture. Discing is full depth or up to 10-inches. Completely dry soil
makes traction nearly non-existent, which is a safety hazard for the equipment operator, and
produces copious amounts of dust to the surrounding area during both discing and grading
operations.
Mowing is routinely conducted during the early summer by City staff for resource enhancement.
Approximately 200 acres are routinely mowed. Outside of the areas mowed for resource
enhancement, large areas are mowed annually in Foothills Park as part of a fuel break. A fuel
break is mowed on Trappers Trail, varying from 100-ft to 300-ft in width. Another area routinely
mowed is along Pony Tracks Fire Road from the intersection of Los Trancos Trail to Page Mill
Road. Most areas are less than 100-ft but the area between Pony Tracks and Los Trancos Trail
can reach 300-ft in width.
Grazing with sheep and goats is a relatively new component of the fuel management program
within the City of Palo Alto Parks. Approximately 5 acres were grazed in 2007 in Las Trampas
Valley in Foothill Park, the picnic areas near the road.
Defensible Space is maintained near existing structures in Foothills Park and Pearson
Arastradero Preserve. This employs the use of hand labor to limb trees and shrubs, cut grass,
landscape with fire-resistant plants, and irrigate selected plants.
Proposed Treatment
Areas
The plan identifies 56 specific areas that are a priority for treatment. The areas generally fall into
the following five categories based upon the treatment proposed: roadside treatments, defensible
space, ignition prevention, firefighter safety zones, and containment fuel breaks. Each treatment
location was selected to achieve a specific objective. Many treatments are associated with
roadsides, structures and City Park/Preserve boundaries. Treatments for containment are
strategically located at ridgetops, in places that have access, are not too steep for mechanical
treatments, avoid riparian areas, and are not prone to soil erosion.
Figure 4: Treatment Areas
Designation Project Description Acreage Treatment Method
Foothills Park Treatment Locations
Evacuation Routes
F.E1 Page Mill Road Within PA City
from
9.54 acres mowing, grazing, hand
labor
Foothills Fire Management Plan Update Page 8 of 46 Mitigated Negative Declaration
Designation Project Description Acreage Treatment Method
Foothills Park Treatment Locations
F.E2 Evacuation Route
-Park Road
Entrance to
Maintenance
5.96 acres mowing, grazing, hand
labor
F.E3 Evacuation Route
-Park North west
Interpretive
Center to
0.57 acres mowing, grazing, hand
labor
F.E4 Evacuation Route
-Park North east
Boronda Lake to
Alexis Drive
1.21 acres mowing, grazing, hand
labor
F.E5 Secondary Evac
Route
Towle
Campground to
0.97
acres
mowing, grazing, hand
labor
F.E6 Los Trancos Southwest
corner of
6.07
acres Hand labor
Firefighter Safety Zone
F.F1 Firefighter Safety
Zone 1
Trappers Ridge
&LosTrancos 0.72 acre mow, graze
F.F2 Firefighter Safety
Zone 2
Trappers Ridge
&MadronFire 0.72 acre mow, graze
F.F3 Firefighter Safety
Zone 3
Trappers Ridge
high point 0.72 acre mow, graze
F.F4 Firefighter Safety
Zone 4
Trapper Ridge
south end 0.72 acre mow, graze
Defensible Space
F.D.1 Defensible Space Entry Gate 0.72 acre hand labor
F.D.2 Defensible Space Station 8 0.72 acre hand labor
F.D.3 Defensible Space Restrooms at
Orchard Glen < ½ acre hand labor
F.D.4 Defensible Space Interpretive
Center 0.11 acre hand labor
F.D.5 Defensible Space Maintenance
Complex 0.72 acre hand labor
F.D.6 Defensible Space Boronda Pump
Station at 0.72 acre hand labor
F.D.7 Defensible Space Dahl Water
Tank < 1/2 acre hand labor, grazing
F.D.8 Defensible Space Boronda Tank < 1/2 acre hand labor, grazing
F.D.9 Defensible Space Park Tank < 1/2 acre hand labor, grazing
Ignition Prevention
F.I.1 Ignition
Prevention
Shady Cove
Picnic Area < 1/4 ac hand labor
F.I.2 Ignition
Prevention
Encinal Picnic
Area < 1/4 ac hand labor
F.I.3 Ignition
Prevention
Pine Gulch
Picnic Area < 1/4 ac hand labor
F.I.4 Ignition
Prevention Orchard Glen < 1/4 ac hand labor
F.I.5 Ignition
Prevention
Oak Grove
Group Picnic < 1/4 ac hand labor
F.I.6 Ignition
Prevention Towle Camp < 1/4 ac hand labor
Foothills Fire Management Plan Update Page 9 of 46 Mitigated Negative Declaration
Designation Project Description Acreage Treatment Method
Foothills Park Treatment Locations
Containment
F.C1 Containment Trappers Trail 72.51 acres mowing, grazing
F.C2 Containment Pony Tracks
south of
1.37
acres
mow annually 10-ft on
either size of road,use a
F.C3 Containment Pony Tracks
north of
1.13
acres mowing, grazing
F.C4 Containment Bobcat point 5.28 acres graze with goats
F.C5 Containment North of entry
Gate 3.47 acres graze with goats
F.C6 Containment "Valley View
Fire Trail"
3.35
acres mowing
Treatment Standards
The proposed clearances of the treatments follow in the table below. The treatments that will
occur within the project area depend on the vegetation type and treatment method.
Figure 5: Treatment Methods and Treatment Intervals
Fuel Treatment Types Dimension Treatment Frequency Comments
Roadside Treatments
Major evacuation routes 30 ft on both sides of
pavement edge
Rotate 3-5+ years
depending on fuel type
Secondary evacuation
routes
15 ft on both sides of
pavement edge
Rotate 3-5+ years
depending on fuel type
Annual for first 10 feet with
grass fuels
Defensible Space 100-ft from structure Annual Follow-up treatments may
not be required annually
Ignition Prevention
10-ft from barbeque Annual
Firefighter Safety Zones
100-ft radius Annual
Containment Fuelbreaks
Within 300-ft of
ridgetop of Trappers
Ridge
Rotate 3-5+ years
Areas designated goat
grazing within park
Rotate 3-5+ years
Area treatment
Two designated potential
prescribed burn units per
map
Rotate 3-5+ years
Perimeter treatment
Foothills Fire Management Plan Update Page 10 of 46 Mitigated Negative
Declaration
- Brush/understory In designated areas
within 300 ft of park
boundary
Rotate 3-5+ years
- Grass Discing or mowing 15-
45 ft from park
boundary, as practical
Annual
- Eucalyptus Removal Individual tree removal One time
Follow up to ensure no
stump sprouts
Timing
The timing of the initial or consecutive treatments is important to achieve the desired fuel
management performance standards and resource management objectives. Given the variable
nature of fuels through changes in weather and season over time, the schedule of the treatment
may often be just as important as the type of treatment selected. For example, treatments in
grasslands typically take place when grass cures or dries out. Cutting grass too early will be
ineffective, as the grass will usually grow back, negating the treatment. Conversely, cutting grass
too late will leave the grass in a hazardous condition during periods of high fire danger. Fuel
treatments also need to be conducted when the weather is not too dry or windy, as some
treatment types, especially mechanical treatments, may inadvertently start fires.
Timing the treatment methods appropriately can reduce potential impacts to special-status
species or sensitive wildlife species. It is likely that there will be some months of the year when
particular practices need to be implemented (e.g., pre-treatment nesting surveys or avoidance of
breeding habitat) to avoid adverse affects to special-status species.
Timing treatments to either control or avoid the spread of invasive plant species or insect pests is
also critical. Treatments should take advantage of differences in the timing of seeding of native
plant species and avoid periods when invasive species are in seed. Pruning of pines and
eucalyptus should be done when insect pests are not flying to minimize the associated spread and
damage from these insects. Pruning should take place from November to April to minimize the
susceptibility to bark beetles or red turpentine beetles. In most cases, the timing and method of
treatment can be modified to accommodate local habitat needs and still reduce fire hazard to an
acceptable level.
Methods
Fuels can be removed on a large scale by prescribed burns, grazing animals, and mechanical
treatment. In small open space areas and around structures, hand labor is effective in reducing
the fuel load. Eucalyptus tree removal may be effective in specific locations of high risk. Fuels
can be redistributed on a large or small scale through mechanical treatments, such as mowing,
discing, or grading. In all the following treatments but hand labor, economies of scale are
dramatic; the larger the project, the greater the efficiency.
1. Hand Labor
Hand labor involves pruning, cutting or removal of weeds or shrubs either by hand or with hand-
held equipment. This process is slow and expensive, but most selective and has little impact
beyond the removal of the target plants. This technique generates considerable debris when
pulling, pruning, and cutting vegetation. The debris is not always removed from the site due to
Foothills Fire Management Plan Update Page 11 of 46 Mitigated Negative
Declaration
the high cost of doing both the clearance and removal by hand. Not removing the debris,
however, leaves a significant hazard, possibly greater than pre-treatment because the debris may
be voluminous, dry, well aerated, and quite flammable. This method is most commonly used by
residents to reduce fuel volume on private lands, or by hand crews on short-term contract with
the City of Palo Alto to reduce hazard adjacent to improvements. Some expertise is required to
work with trouble species such as poison oak, to prune oaks and control shrubs, and to identify
new fuel hazards as they arise. Hand labor encompasses the operations of pruning and weed-
whipping, tree removal, pruning, bark pulling, removal of dead wood within the tree/shrub
canopy, litter removal and mulching, and establishing new plant material. Hand labor allows use
of a wide variety of methods to reduce fuel load, including both chemical and mechanical
treatments.
Pruning
Pruning Trees and shrubs must be hand-pruned to vertically separate fuels. Pruning lower
branches of trees is usually done with a hand-held pole saw (with or without a motorized chain
saw attached). Lower branches on shorter trees can be pruned with loppers.
Weed Whipping
Like mowing, weed whipping reduces fire hazard by reducing the fuel height. However, it is
done by hand to avoid harming rock outcrops and desired small plants (such as oak regeneration
and landscape material). This treatment is generally limited to small material such as grass or
short herbs. Weed whipping may be accomplished any time of the year, and regardless of
whether the material has cured.
Weed whipping is performed with a hand-held, gas powered tool that cuts grasses and very thin
woody material with a fast-spinning fishing-line type of cutter. Because this method is
performed manually, it can be used to selectively remove certain vegetation. Most large woody
stems are not cut by the treatment, however seedlings (such as oak seedlings) can be severely
damaged. Treatments can be completed with greater care than the others (however the height to
which plants are cut may be difficult to control if the operator is not experienced) and minimize
soil disturbance and erosion. It is also often the only type of treatment possible on steep slopes
and in wooded areas. The average weed whipping rate is 750 square feet/hour.
The schedule for a skilled laborer should be tailored to the timing of their tasks. For example,
selective weed whipping of annual grasses before they set seed while leaving native bunch
grasses until after these plants set seed can shift the proportion of vegetative cover over time to
more bunch grasses. This shift in type of grasses can shorten the length of time the landscape is
prone to ignition. Similarly, thistle reproduction can be minimized by cutting while they are
growing, but before they set seed. Pruning should be done from November to April; this
schedule avoids spreading destructive bark beetles and/or other pathogens.
2. Mechanical Treatments
Mechanical treatments, including mowing, weed whipping, discing, and grading, rearrange
rather than reduce the actual fuel load. Heavy machinery is usually used in flat areas where
terrain and the presence of rocks or numerous trees do not prohibit travel. This type of
Foothills Fire Management Plan Update Page 12 of 46 Mitigated Negative
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machinery should not be used on slopes over 30% because of concerns for worker safety as well
as erosion control and slope stability issues.
Heavy Machinery
Heavy machinery generally means tractors with attachments, such as brush hogs, flail, mowers,
and tiger mowers. A variety of attachments serve numerous purposes. For example, a brush hog
attachment cuts and breaks brush plants off and produces a mulch of the brush debris. Mowers
that cut or flail grass and small woody plants are also attached to tractors. Attachments (such as
mowers) with articulated arms that reach as far as 20 ft away from the tractor reduce the area
over which the tracks must travel, and offer more maneuverability. These articulated arms also
cut and/or break off material. Heavy machinery is a moderately fast, and a relatively
inexpensive treatment. There is little control over which plants are cut, but machines can travel
around isolated areas of concern.
Heavy machinery should not be used when the ground is soft in order to prevent ruts and bared
soil. Soil movement can be caused by all users on foot, bicycle, equestrian and vehicles (patrol
vehicles and fire apparatus). Soil movement can be ruts or minor depressions, which will lead to
large ruts or voids. This technique can be used at almost any other time of year, but is faster
when done in the summer or fall when brush is brittle and grass has cured. It must not be used
during times of high fire danger because the machines can start fires. The under-carriage of the
machine and attachments should be washed off after use in areas of weed infestations.
Grading and Discing
Grading and discing involves stripping a swath of land bare of vegetation with a tractor and
blade. It is very effective in producing fire trails 8 to 12 feet across and as a maintenance tool for
access routes. Generally, grading is done mid-spring, by a contractor when there is still residual
moisture in the soil, but after the threat of spring rains has diminished. Residual soil moisture
makes the soil pliable or workable, and allows the soil to compact. When grading is performed
when the soil is completely dry, the soil is very difficult to work. Pearson Arastradero has high
clay content soils and causes premature soil movement unless the contractor supplements soil
moisture with a water truck, which is an additional expense.
There are several disadvantages to this treatment type; by removing all competing vegetation,
grading creates an excellent establishment site for weedy species, which may be serious fire
hazards. Untimely grading, for example, in mid-summer, can help sow seeds of weedy exotics,
such as yellow star thistle, mustard and Italian thistle. In addition, annual grading causes soil
disturbance and alters drainage patterns. Runoff, blocked from cross-drainage by the banks on
either side of a graded fire trail, is redirected down the trail. This situation favors coyote bush
and exotic grasses, leading to a shift in the grassland species composition. Grading spoils will
need to be feathered into the sides or smoothed back into grading area annually.
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Figure 6: Proposed Treatment Areas for Foothill Park
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Figure 7: Proposed Treatment Areas for Pearson Arastradero Preserve
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Discing involves cultivating or turning over the upper 10" of soil, and produces an uneven
surface with a discontinuous fuel distribution and is appropriate only if mowing or grazing is not
applicable that year or in a specific location. Rate of production is quite high; normally the
operator can disc land parcels of two acres or less within one day. Discing is normally
performed annually once grass has cured (so the grass will not grow back that season). A tractor
with discer attachment can typically cultivate a swatch 15 feet wide in a single pass. While this
is an effective barrier to surface fire spread, it is also an ideal disturbed area with prime growing
conditions for weeds and distribution of their seeds. Surface erosion can be significant in areas
prone to this process.
3. Grazing with Sheep and Goats
The grazing method includes the intentional use of sheep and goats to consume vegetation thus
reducing the amount or density of fuel. These types of livestock are not recommended to create
a fuel break, but can be used to maintain this type of pre-suppression feature. Similarly,
livestock can prevent grasslands from shrub encroachment, and an oak woodland free of
significant understory. The option is effective where the plants are palatable to the animals
selected. Control of the livestock and prevention of the impacts of overgrazing is critical to
successful use of this technique. As a fuel management technique, livestock need not graze
every year.
Grazing can reduce or encourage weedy pest plants depending on the timing and intensity of
grazing. A range management plan and a grazing monitoring program needs to be established to
identify the impacts and ensure that the animals are removed once fuel management goals are
met. Perennial grasses may require modifications from management of annual grasses using
grazing animals. Because presence of healthy perennial grass stands has many benefits, these
modifications are generally recommended. The benefits of perennial grasses are that they cure
later in the season, which limits the opportunity for ignition. Mowing typically can be scheduled
over a longer time period. Rotation of grazing animals is preferred over greater grazing pressure.
Typically, perennial grasses react best when grazing is applied after seed maturation - from late
spring through the fall. Goats may import seeds from another weedy site. The herd can be
quarantined at goat herd’s ranch for three days where they will be fed alfalfa to clear out their
systems. The herder can also use short-haired goats that will carry fewer seeds in their fur.
The herding instinct of sheep and goats allows professional herders to range in very mobile
bands without the installation and maintenance of permanent fences. Portable electric fences are
commonly used to help control the herd and the outcome of their grazing. Goats will browse
materials up to 6 feet above the ground creating a desirable vertical separation between the
canopy and ground cover. However, measures must be taken to prevent girdling of trees by
goats browsing on bark. Herd movement has the advantage of breaking off dead material in a
stand as well as punching a humus layer into the soil (if the ground is somewhat moist) and
thereby removing available fuel. Grazing treatments need to be repeated, however, following up
or alternating with a different, complementary technique can extend its effectiveness.
If work is needed to be done during May-July, scheduling can present a challenge because many
clients in the greater area desire the service at that time. To minimize the negative effects of
Foothills Fire Management Plan Update Page 16 of 46 Mitigated Negative
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grazing on a specific plant, goats should graze after seed set of that particular plant. During
initial fuel reduction treatments, goats may be most cost-effective in the late fall or early spring
when demand for their services, and possibly price are reduced. Multi-year contracts, and
contracts for larger areas typically lower the costs per acre. Providing a place where the herd can
stay during the winter also lowers costs for treatment. Providing a water source for livestock is
another way to reduce costs. Water sources can be as rudimentary as a plastic wading pool or a
portable trough.
4. Broadcast Prescribed Burns
Prescribed burning reintroduces fire into the ecosystem as a "natural treatment" and can promote
native flora and aid containment of fires by reducing fuel volumes. Prescribed burns are usually
performed by the local fire protection district. CalFire may be willing to participate in a limited
prescribed burning program as part of their hazard reduction efforts within the Vegetation
Management Program, even though the project area would be outside the State Responsibility
Area. If burns were conducted by CalFire, the State would not only assume liability, but also
share costs. Regardless, it is likely that CalFire and other nearby fire protection districts and
departments would offer mutual cooperation and/or assistance.
Several precautions, such as installing firebreaks and notifying various agencies, must be taken
before performing a prescribed burn. Treatment boundaries are often road and trail crossings,
which reduces the number of fire breaks that need to be created by fire personnel, thereby
reducing labor costs and time needed to prepare for the burn as well as minimizing the amount of
surface soil disturbance and potential for soil erosion.
Prescribed burning requires the development and approval of a prescription or burn plan, which
is typically developed by the local fire protection district in consideration of fuel reduction
requirements, local weather conditions, and available resources for fire management. The soot
and smoke generated, as well as the chance of escape, make prescribed burns a public safety
concern. Planning and coordination with interested parties must be an integral part of the
program.
Broadcast burning may occur throughout the year; however, it is usually conducted during late
spring when the ground is still wet or during fall or winter after plants have completed their
yearly growth cycle and their moisture content has declined. Spring burns are preferred by some
fire staff to ensure a greater measure of public safety, however, there may be impacts to animal
and plant reproduction activities. Fall burns are more closely aligned with the natural fire cycle
found in California. If a prescribed burn were to be conducted in the fall, the period before
leaves or new herbaceous material covers the slopes will be short (possibly a month or two).
Prescribed burning can enhance the local grasslands and promote the abundance of wildflowers.
Any small oaks or shrubs to be retained will need to be protected during the burn to prevent their
mortality. While the abundance of wildflowers the subsequent years is an appealing sight, the
burned area will be temporarily blackened.
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5. Eucalyptus Tree Removal
By removing eucalyptus trees their canopy no longer contributes to a fire in the form of a crown
fire or ember production. Additionally the production of surface fuels is reduced since biomass
production (branches, leaves, duff etc.) is decreased. This technique has positive impact on
reducing spotting potential, heat output, spread rate and, potentially, ignitability depending upon
what replaces the overstory.
Tree removal varies from cutting of individual trees, to removal of entire overstory canopy. This
process can be slow and expensive, but can be selective with limited impact beyond the removal
of the target plants (depending upon scale of removal). Sometimes harvesting techniques can be
quite rapid. If the whole tree is not harvested, the technique generates considerable debris (from
tree branches) that should be removed using machinery to haul. The boles of trees hauled away
and other debris should be either hauled away or may be burned later as a part of a prescribed
burn (pile or broadcast). A portion of debris may be left as a sort of erosion control measure and
to cover bare spots.
And bats may use eucalyptus trees as perches and nesting sites. Replacement perches and
nesting platforms for raptors can be constructed, located, and installed prior to removal of the
trees to minimize displacement of raptors. If the tree harbors a maternal bat roost, removal
should be coordinated with the appropriate wildlife agencies, including the California
Department of Fish and Game and possibly the US Fish and Wildlife Service. Volunteers can
locate and construct the raptor perches and nesting platforms, with guidance from suitable
experts (e.g. Audubon Society or the Point Reyes Bird Observatory).
Tree removal creates patches of disturbance by the removal operation. Subsequent treatment of
the area is dependent upon the species that encroach into these patches. Removal of exotics or
weed species on an annual basis should be anticipated until an acceptable stable vegetation type
is re-established.
Sprout removal is often required as a follow up treatment, involving the application of herbicides
and/or other techniques such as grinding the stump or placing plastic over the stump.
6. Herbicide Application
Using herbicides to control invasive plant species that exacerbate wildfire risk is used as part of
an Integrated Pest Management1 program and in combination with other treatment measures
(e.g., mowing, burning and hand removal). Application following another treatment method in
which plants are trimmed or shortened can increase the effectiveness of the chemical treatment.
Herbicides can also be used to kill herbaceous plants in exposed areas, such as roadside grass
and weeds, and are typically applied while the grasses and weeds are still actively growing.
Foliar treatments are generally not applied within seven days of significant rain because the
herbicide may be washed off before it is effective, and not on windy days because of concerns
for spray drift.
1 Integrated Pest Management is a strategy that uses an array of biological, mechanical, cultural, and hand labor, to control
pests, with the use of herbicides as a least-preferred method of control.
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The use of Garlon 4 Ultra herbicide can be used to treat areas of eucalyptus resprouting,
removing the need to completely uproot or grind down the eucalyptus stump. Foliar application
of Roundup to eucalyptus re-sprouts is another typical, successful chemical treatment, and can be
used to eliminate small-diameter fuels in areas of high ignition risk. The use of a thistle-specific
herbicide, Transline, is effective in controlling the spread of yellow star thistle, artichoke thistle,
and bull thistle.
Herbicides do not remove any vegetation from an area’s fuel load; the dead plant matter
continues to exist at the site and could continue to be a fire hazard if not collected and disposed.
Health, safety and environmental concerns have limited the widespread use of chemicals over the
past 20 years, and repeated use of chemicals is not preferred due to the prevalence of unwanted
species building resistance to herbicides. Additionally, concerns regarding water quality and
other potential environmental impacts that may occur with prolonged use of and exposure to
herbicides and other chemical applications further limit their frequent or widespread use as a
treatment.
Application of herbicides is typically performed by hand, and can include sponging, spraying, or
dusting chemicals onto unwanted plants. Hand application provides flexibility in application and
is ideally suited for small treatment areas. Roadside application of herbicides may employ a
boom affixed to or towed behind a vehicle. Herbicide application requires specific storage,
training and licensing to ensure proper and safe use, handling, and storage. Only personnel with
the appropriate license are allowed to use chemicals to treat vegetation. Herbicide application is
also only applied per a prescription prepared by a Pesticide Advisor licensed in that county.
Personal protection equipment is essential to limit personnel exposure to chemicals.
10. SURROUNDING LAND USES AND SETTING
The two parks, Foothills (1400 acres) and Pearson Arastradero (609 acres), make up
approximately 2000 acres of the Santa Cruz Mountains. Foothills Park ranges in elevation from
about 600 to 1800 feet above mean sea level and for Pearson Arastradero, from 300 to 750 feet
above mean sea level. Both parks are heavily vegetated and contain various plant communities
and a diversity of habitat for abundant wildlife. The surrounding land uses are open space (public
and private), private residences in the Town of los Altos, City of Palo Alto and Santa Clara
County, and a private golf course/country club.
11. OTHER PUBLIC AGENCIES
• Department of Fish and Game
• Santa Clara County Agricultural Commission
• Bay Area Air Quality Management District
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ENVIRONMENTAL CHECKLIST AND DISCUSSION OF IMPACTS
EVALUATION OF ENVIRONMENTAL IMPACTS
1) A brief explanation is required for all answers except "No Impact" answers that are adequately supported by
the information sources a lead agency cites in the parentheses following each question. [A "No Impact"
answer is adequately supported if the referenced information sources show that the impact simply does
not apply to projects like the one involved (e. g. the project falls outside a fault rupture zone). A "No
Impact" answer should be explained where it is based on project-specific factors as well as general
standards (e. g. the project will not expose sensitive receptors to pollutants, based on a project-specific
screening analysis).]
2) All answers must take account of the whole action involved, including off-site as well as on-site, cumulative
as well as project-level, indirect as well as direct, and construction as well as operational impacts.
3) Once the lead agency has determined that a particular physical impact may occur, then the checklist answers
must indicate whether the impact is potentially significant, less than significant with mitigation, or less than
significant. Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be
significant. If there are one or more “Potentially Significant Impact” entries when the determination is made,
an EIR is required.
4) “(Mitigated) Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the
incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less
than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how
they reduce the effect to a less than significant level (mitigation measures from Section 17, “Earlier
Analysis,” may be cross-referenced).
5) Earlier analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect
has been adequately analyzed in an earlier EIR or negative declaration. Section 15063 (C)(3)(D). In this
case, a brief discussion should identify the following:
a) Earlier Analysis Used. Identify and state where they are available for review.
b) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of
and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether
such effects were addressed by mitigation measures based on the earlier analysis.
c) Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated,”
describe the mitigation measures which were incorporated or refined from the earlier document and the
extent to which they address site-specific conditions for the project.
6) Lead agencies are encouraged to incorporate into the checklist references to information sources for potential
impacts (e.g. general plans, zoning ordinances). Reference to a previously prepared or outside document
should, where appropriate, include a reference to the page or pages where the statement is substantiated.
7) Supporting Information Sources: A source list should be attached, and other sources used or individuals
contacted should be cited in the discussion.
8) The explanation of each issue should identify:
a) the significance criteria or threshold, if any, used to evaluate each question; and
b) the mitigation measure identified, if any, to reduce the impact to less than significance.
Foothills Fire Management Plan Update Page 20 of 46 Mitigated Negative
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DISCUSSION OF IMPACTS
The following Environmental Checklist was used to identify environmental impacts, which could occur if the
proposed project is implemented. The left-hand column in the checklist lists the source(s) for the answer to each
question. The sources cited are identified at the end of the checklist. Discussions of the basis for each answer and
a discussion of mitigation measures that are proposed to reduce potential significant impacts are included.
A. AESTHETICS
Issues and Supporting Information
Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Substantially degrade the existing visual
character or quality of the site and its
surroundings?
1, 4
3
b) Have a substantial adverse effect on a
public view or view corridor?
1, 2-Map
L4, 4
3
c) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within
a state scenic highway?
1, 2-Map
L4,4
3
d) Violate existing Comprehensive Plan
policies regarding visual resources?
1, 2, 4 3
e) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
1,4
3
f) Substantially shadow public open space
(other than public streets and adjacent
sidewalks) between 9:00 a.m. and 3:00
p.m. from September 21 to March 21?
1, 2, 4
3
DISCUSSION:
The Plan specifies 56 treatment areas (Figures 6 & 7) and associated fuel management categories:
roadside treatments along potential evacuation corridors, creation and maintenance of firefighter safety
zones, creation and maintenance of defensible space around structures in the parks, fire ignition
prevention, and treatments to aid containment of fires in and within the park. The proposed fuel
treatment methods (e.g. grazing, mowing, discing) are confined to a specific dimension, as detailed in
Figure 5, for each of the treatment areas. The Comprehensive Plan designates Arastradero and Page Mill
Road and Skyline Boulevard as scenic routes; Skyline is also a State Scenic Highway. The proposed fuel
treatment methods (hand labor, mechanical, grazing, prescribed burns, eucalyptus removal, and
herbicides) would not significantly degrade the existing visual character of the parks or road segments.
The fuel treatment method that may have a temporary visual impact to the Pearson Arastradero Preserve
would be the prescribed burns. The Plan calls for two areas, see Figure 7, in Pearson Arastradero
Preserve to be treated with prescribed burns on a 3-5+ year rotation. After the burn occurs, the area will
be blackened, but only for a temporary period. Prescribed burning is known to enhance the local
grasslands and promote an abundance of wildflowers. All treatment areas are confined to a limited
dimension to attain basic fire safety. Much of the area that is proposed for treatment has undergone fuel
Foothills Fire Management Plan Update Page 21 of 46 Mitigated Negative
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management treatments on a periodic basis since the original 1982 fire management plan was adopted
and the expansion of treatment areas is not anticipated to create a significant aesthetic impact.
Mitigation Measures: None Required
B. AGRICULTURAL RESOURCES
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may
refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California
Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland.
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on the maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use?
1, 3, 4
3
b) Conflict with existing zoning for agricultural
use, or a Williamson Act contract? 1, 2-Map
L9, 4
3
c) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to non-agricultural use?
1, 4
3
DISCUSSION:
The project area is not located in a “Prime Farmland,” “Unique Farmland,” or “Farmland of Statewide
Importance” area, as shown on the maps prepared for the Farmland Mapping and Monitoring Program
of the California Resources Agency. The project area is not zoned for agricultural use, and is not
regulated by the Williamson Act.
Mitigation Measures: None Required
C. AIR QUALITY
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with or obstruct with implementation
of the applicable air quality plan (1982 Bay
Area Air Quality Plan & 2000 Clean Air Plan)?
1, 4
3
b) Violate any air quality standard or contribute
substantially to an existing or projected air
quality violation indicated by the following:
i. Direct and/or indirect operational
Foothills Fire Management Plan Update Page 22 of 46 Mitigated Negative
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Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
emissions that exceed the Bay Area Air
Quality Management District (BAAQMD)
criteria air pollutants of 80 pounds per day
and/or 15 tons per year for nitrogen oxides
(NO), reactive organic gases (ROG), and
fine particulate matter of less than 10
microns in diameter (PM10);
1, 4 3
ii. Contribute to carbon monoxide (CO)
concentrations exceeding the State
Ambient Air Quality Standard of nine
parts per million (ppm) averaged over
eight hours or 20 ppm for one hour( as
demonstrated by CALINE4 modeling,
which would be performed when a) project
CO emissions exceed 550 pounds per day
or 100 tons per year; or b) project traffic
would impact intersections or roadway
links operating at Level of Service (LOS)
D, E or F or would cause LOS to decline to
D, E or F; or c) project would increase
traffic volumes on nearby roadways by
10% or more)?
1, 4
3
c) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non-attainment under an
applicable federal or state ambient air quality
standard (including releasing emissions which
exceed quantitative thresholds for ozone
precursors)?
1, 4
3
d) Expose sensitive receptors to substantial levels
of toxic air contaminants?
1, 4
3
i. Probability of contracting cancer for the
Maximally Exposed Individual (MEI)
exceeds 10 in one million
1, 4
3
ii. Ground-level concentrations of non-
carcinogenic TACs would result in a
hazard index greater than one (1) for the
MEI
1, 4
3
e) Create objectionable odors affecting a
substantial number of people?
1, 4
3
f) Not implement all applicable construction
emission control measures recommended in the
Bay Area Air Quality Management District
CEQA Guidelines?
1, 4
3
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DISCUSSION:
The proposed fuel management treatments (hand labor, mechanical equipment, grazing, prescription
burns, herbicide application, eucalyptus tree removal) are generally low to no impact on the overall air
quality, with exception of the prescribed fires. All prescribed burns must go through a permit review
process with the Bay Area Air Quality Management District (BAAQMD) before a burn is permitted.
The BAAQMD will determine whether it is a burn day, and has the authority to permit burning when the
prescription has been reached. The burn day determination maximizes the dispersal and dilution of
smoke. Prescribed fires may be executed on non-burn days as necessitated by logistic concerns.
Logistic concerns may include expected end-of-season precipitation, availability of personnel, or narrow
prescriptions. The Prescribed Fire Incident Commander will conduct a test burn to determine if smoke
dispersal requirements in the Smoke Management Plan are being met prior to starting ignition of the
burn plot.
Based on the Bay Area Air Quality Management District’s thresholds, it is not anticipated that the project would affect any regional air quality plan or standards, or result in a cumulatively considerable net increase of any criteria pollutant.
Mitigation Measures: None Required
D. BIOLOGICAL RESOURCES
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect, either
directly or through habitat modifications, on
any species identified as a candidate, sensitive,
or special status species in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Game or
U.S. Fish and Wildlife Service?
1, 2-Map
N1, 4, 5
3
b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional plans,
policies, regulations, including federally
protected wetlands as defined by Section 404
of the Clean Water Act (including, but not
limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological
interruption, or other means?
1, 2-Map
N1, 4, 5
3
c) Interfere substantially with the movement of
any native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use
of native wildlife nursery sites?
1, 2-Map
N1, 4, 5
3
d) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or as defined by the City of
1, 2, 4, 5
3
Foothills Fire Management Plan Update Page 24 of 46 Mitigated Negative
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Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Palo Alto’s Tree Preservation Ordinance
(Municipal Code Section 8.10)?
e) Conflict with any applicable Habitat
Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
1, 2, 4,5
3
DISCUSSION:
Foothills Park and Pearson Arastradero Preserve provide habitat for a broad range of wildlife and plants,
including some designated as protected or sensitive either by the State of California or through Federal
designation. The Foothills Fire Management Plan will not result in adverse impacts to any special-status
species with mitigation incorporated. The special-status species that are known to occur in the Foothills
Fire Management Plan area are Steelhead, San Francisco dusky-footed woodrat, white-tailed kite,
arcuate bush mallow, and western leatherwood. Suitable habitat for several others exists, but their
presence has not been verified. The Plan will not have a substantial adverse effect on any riparian
habitat or other sensitive natural community. The amount of vegetation that will be trimmed represents
a minor amount of the riparian zone, and will not result in the permanent removal of riparian habitat.
Adverse effects to arroyo willow riparian are not expected. Measures to protect wetland values from
mowing and grazing are recommended (see measure BIO-8). The Plan incorporates mitigation so as to
not have an adverse impact on wetlands. Wetlands occur in Pearson Arastradero Preserve and at
Boronda Lake in Foothills Park. Implementation of the Foothills Fire Management Plan will not result
in the removal or filling of wetlands, and will not affect their hydrology. Wetlands could be affected by
the following treatments: A.E. 1 (Arastradero Road adjacent to the Preserve to be treated with mowing,
grazing and hand labor), A.Rx. 1 and A.Rx.2 (prescribed fire in the middle of the Preserve), A.C.3
(grazing the grassland on the parking lot side of the Preserve), and A.C.11 (mowing Meadow Lark to
Juan Bautista Trail). Measure BIO-9 is proposed to be included in the Fire Management Plan, which is
to avoid mowing or weed-whipping wetlands, and to incorporate wetland protection measures in the
grazing management plan required in the fire management plan.
The Plan does not propose activities in stream courses that would impede any fish passage and does not
require the construction of any structures that would block wildlife movement. The area that the Plan
covers is not within an area subject to a Habitat Conservation Plan or any similar approved planning
document.
Activities proposed in the Foothills Fire Management Plan are subject to the City of Palo Alto’s
municipal code with regard to tree removal. Trimming or removal of coast live oak trees are subject to
the requirements of Title 8, which include limits on trimming to less than 25 percent of the tree canopy
and that the trimming not unbalance the tree. The Fire Management Plan may result in the removal or
trimming of protected trees. Measure BIO-8 is included to require that trimming follow the tree
preservation ordinance. With this measure included, the Fire Management Plan will comply with local
ordinances protecting biological resources.
Foothills Fire Management Plan Update Page 25 of 46 Mitigated Negative
Declaration
In order to reduce the impacts from the proposed fuel management treatments, the following mitigations
are proposed to reduce the impacts to a less than significant level.
Mitigation Measures:
BIO - 1: A qualified biologist2 or park staff trained to do so by a qualified biologist shall conduct a
tail-gate training session to all relevant personnel who will be performing treatments regarding protected
species and habitats in the project area, the limitations on areas that can be accessed on foot or with
equipment, and the legal consequences of take of protected species or habitat. The training shall be
repeated for new personnel coming to the project site. Dogs shall be prohibited from the project site.
BIO - 2: Vegetation removal in any vegetation type from February 15 to August 31 shall require a
survey for nesting birds by a qualified biologist or by park staff trained to do so by a qualified biologist
and avoiding removal of nests in active use. If raptor nests are detected, a buffer area will need to be
established around the nest in consultation with the California Department of Fish and Game. The
buffer may be 250 feet.
BIO - 3: Vegetation removal in areas of serpentine soil, oak woodland, chaparral, coastal scrub
and riparian forest habitats shall require a survey for rare plant species by a qualified biologist/ botanist
prior to vegetation removal. Known rare plant locations should be treated in a way that benefits the rare
species. This may include limiting the area of treatment in order to provide a buffer around the plant(s),
or may include selectively trimming competitive vegetation adjacent to the plant(s). Some species may
benefit from disturbance; the specific actions to be taken should be determined in consultation with a
botanist. The plant survey shall be performed during the bloom period. After surveys in the same
locations over three separate years, subsequent surveys are not necessary in that area unless there a
newly listed plant species could occur in the habitat. This should be determined by consulting the
California Department of Fish and Game.
BIO - 4: Vegetation removal, including dead and downed debris, shall require a survey for
presence of San Francisco dusky-footed woodrat by a qualified biologist or by park staff trained to
identify woodrat houses by a qualified biologist. If woodrat houses are found, disturbance should be
avoided and a minimum five-foot buffer should be provided around the house. If, for public safety
reasons, it is necessary to move the house, the process must be coordinated with the California
Department of Fish and Game. All relevant workers shall receive instruction regarding woodrat houses
prior to their start of work.
BIO - 5: Prior to the removal of any tree that is 12 inches or more in diameter breast height, a
survey for perennial bat roosts and, during the breeding season from February 15 to August 31, raptor
nests shall be conducted by a qualified biologist or park staff trained by a qualified biologist to identify
these resources is required. If present, removal cannot continue without CDFG guidance.
BIO - 6: Discing within 500 feet of a lake, pond or creek, shall require a biological survey to
determine impacts to California red-legged frog, California tiger salamander, San Francisco garter snake
and Western pond turtle and whether permits are required from the USFWS/CDFG.
2 A “qualified biologist” is a person with demonstrated ability to identify special-status plant and/or animal species in the San
Francisco Bay Area.
Foothills Fire Management Plan Update Page 26 of 46 Mitigated Negative
Declaration
BIO - 7: Discing in grassland shall require a pre-construction survey for American badger,
California red-legged frog and burrowing owl by a qualified biologist.
BIO - 8: Trimming of coast live oaks shall follow the City’s Tree Ordinance (Title 8). Coast live
oak or Valley oaks that are 11.5 inches in diameter or more measured at 54 inches above grade may not
be removed without a permit, and may not be pruned such that more than 25 percent of the crown is
removed or the tree is left unbalanced.
BIO - 9: Wetlands mapped in Pearson Arastradero Preserve shall be avoided when weed-whipping
or mowing. Modify the Fire Management Plan Best Management Practice that requires that a grazing
plan be prepared to include protection of drainages and wetlands from the impacts of grazing animals.
BIO - 10: For treatments in Foothills Park or on Page Mill Road along the Park border, a pre-work
survey for stands of locally important plants shall be conducted, and the plants avoided as long as it does
not impair public safety. Field crews shall be educated about the sensitivity of these plant species. For
additional information, see Table 3 in Appendix A of the Biological Assessment (Source Reference #5).
BIO - 11: For proposed treatments, clean all tools and equipment following actions and prior to
movement into new environmental areas to prevent the spread of invasive or non-native plants.
BIO - 12: Measures shall be taken to clean equipment, tires, and shoes to prevent the spread of
Sudden Oak Death, and that any materials infected with the disease be disposed of in accordance with
State or County Agricultural Commission guidelines. To reduce the possibility of spreading the disease,
it is recommended that work not be done in wet or muddy conditions, and that infested areas be avoided
to the extent feasible. Additional guidelines are available from the County Agricultural Commissioner.
BIO - 13: A qualified biologist shall be present onsite to monitor all treatment work. The biological
monitor shall have the authority to stop work if deemed necessary to protect state or federally protected
species, and shall work directly with the City staff. Prior to the start of work each day, the monitor shall
thoroughly inspect the treatment area and adjacent habitat areas to determine if any protected species are
present in the area and shall remain onsite through out the day while work activities are occurring. If a
protected species is encountered, the onsite biological monitor shall determine whether treatment
activities are remote enough from the animal that it will not be harmed or harassed.
BIO - 14: Treatment equipment and materials shall be staged in an already disturbed area such as
improved trails or existing roads.
BIO - 15: Prior to introduction, all grazing animals shall be quarantined for three days and fed
weed-free forage to limit spread of invasive or unwanted plant species, as well as prevent spread of
livestock diseases.
BIO - 16: Grazing shall be limited to non-riparian areas.
Foothills Fire Management Plan Update Page 27 of 46 Mitigated Negative
Declaration
BIO - 17: Maintain a buffer between the prescribed burn area and water bodies or drainage into
riparian zones. Buffers should be a minimum of 25 feet for 5% slopes, 75 feet for 5-10% slopes, and
250 feet for 10% or greater slopes. No prescribed fires shall be ignited near streams or in riparian zones.
BIO - 18: Herbicide treatments within habitat of California Red-legged Frog shall be conducted
according to U.S. District Court injunction and order covering 66 pesticides (Oct 2006) and subsequent
EPA effects determinations.
BIO - 19: Avoid herbicide treatments in areas adjacent to water bodies, riparian areas, and primary
drainage access. Follow all herbicide labels and directions in determining applications near water
resources or riparian habitats. Limit aerial application to greater than 100 feet from water resources.
Limit ground and hand application to greater than 50 feet.
Significance after Mitigation: Less Than Significant
E. CULTURAL RESOURCES
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Directly or indirectly destroy a local cultural
resource that is recognized by City Council
resolution?
1, 2-Map
L7, 4
3
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to 15064.5?
1, 2-Map
L8, 4
3
c) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
1, 4
3
d) Disturb any human remains, including those
interred outside of formal cemeteries? 1, 2-Map
L8, 4
3
e) Adversely affect a historic resource listed or
eligible for listing on the National and/or
California Register, or listed on the City’s
Historic Inventory?
1, 2-Map
L7, 4
3
f) Eliminate important examples of major periods
of California history or prehistory?
1, 4 3
DISCUSSION:
There are no known archaeological or human remains located in this area. It is unlikely that the Native
Americans would have established permanent camps away from the Bay, with its abundant food source.
However, they probably did travel to the foothills to hunt and gather plant material. If, during any
treatment activities, any archaeological or human remains are encountered, all activity shall cease and a
qualified archaeologist shall visit the site to address the find. The Santa Clara County Medical
Examiner and Native American Heritage Commission of the State of California shall be notified in order
to receive the appropriate direction on how to proceed.
Foothills Fire Management Plan Update Page 28 of 46 Mitigated Negative
Declaration
Mitigation Measures: None Required
F. GEOLOGY, SOILS AND SEISMICITY
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Expose people or structures to potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault
Zoning Map issued by the State
Geologist for the area or based on
other substantial evidence of a known
fault? Refer to Division of Mines and
Geology Special Publication 42.
1, 4
3
ii) Strong seismic ground shaking? 2-Map
N10, 4
3
iii) Seismic-related ground failure,
including liquefaction?
2-Map
N5, 4
3
iv) Landslides? 2-Map
N5
3
b) Result in substantial soil erosion or the loss
of topsoil?
1, 4
3
c) Result in substantial siltation? 1, 4 3
d) Be located on a geologic unit or soil that is
unstable, or that would become unstable as
a result of the project, and potentially
result in on- or off-site landslide, lateral
spreading, subsidence, liquefaction or
collapse?
2-Map
N5, 4
3
e) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building
Code (1994), creating substantial risks to
life or property?
2-Map
N5, 4
3
f) Have soils incapable of adequately
supporting the use of septic tanks or
alternative waste water disposal systems
where sewers are not available for the
disposal of waste water?
1, 4
3
g) Expose people or property to major
geologic hazards that cannot be mitigated
through the use of standard engineering
1, 2-Map
N5, 4
3
Foothills Fire Management Plan Update Page 29 of 46 Mitigated Negative
Declaration
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
design and seismic safety techniques?
DISCUSSION:
The entire state of California is in a seismically active area. The proposed Plan would not expose people
to substantial adverse risks of loss, injury, or death since the proposed project does not include habitable
construction of any kind. However, the project area is located in an area that would experience a range
of weak to very violent shaking in the event of a major earthquake. The area also has the potential for
earthquake induced landslides especially where sloped, and surface rupture along fault traces.
The two parks have soils that vary in degrees of potential erosion hazard (see Figure 8). The proposed
fuel treatments (hand labor, mechanical equipment, grazing, prescription burns, herbicide application,
eucalyptus tree removal) in themselves create some degree of erosion potential due to the disturbance of
the existing vegetation and surface area. Erosion control methods and stormwater pollution protection
measures should be used where appropriate. The purpose is to control sediment and minimize potential
water quality impacts. The following mitigation measures must be followed to address potential soil
erosion impacts to a less than significant threshold.
Figure 8: Soil Types in Foothills Park and Pearson Arastradero Preserve
Soil Mapping Unit Soil Name Location Erosion Hazard
Los Gatos Gravelly Loam Foothills Park & Pearson
Arastradero Preserve
Very High
Los Gatos-Maymen Complex
(50-75% slope) Maymen Rocky Fine
Sandy Loam
Foothills Park Very High
Los Gatos Clay Loam (15-
30% slope)
Los Gatos Clay Loam Foothills Park Moderate
Los Osos Clay Loam (15-30%
slope)
Los Osos Clay Loam Pearson Arastradero
Preserve
Moderate
Azule Clay Loam (15-30%) Azule Loam Pearson Arastradero
Preserve
Slight to Moderate
Cropley Clay (2-9% slope) Cropley Clay Foothills Park Slight
Pacheco Clay Loam Pacheco Clay Loam Pearson Arastradero
Preserve
Slight
Pleasanton Loam Pleasanton Loam Pearson Arastradero
Preserve
Slight
Mitigation Measures:
Geology - 1: The City shall conduct treatment actions in a manner that avoids erosion and adverse
affects on sensitive soil systems by avoiding treatment in sensitive soils and potentially
erosive soil areas. This mitigation measure shall be implemented through development
of a study that identifies all potentially erosive soils prior to beginning treatment actions
and development of an erosion control plan subject to review and approval of City Staff
that restricts treatment operations that may adversely affect the sensitive soil systems.
Foothills Fire Management Plan Update Page 30 of 46 Mitigated Negative
Declaration
Geology - 2: Avoid treatment actions during periods of precipitation, or immediately following severe
weather.
Geology - 3: (Hand Labor) Avoid excessive foot or vehicle traffic on slopes, unimproved or non-
designated trails, or outside of preexisting roads or access points.
Geology - 4: (Mechanical). In addition to avoiding treatment actions during periods of precipitation, or
immediately following severe weather, avoid scheduling any treatment actions during
seasons with significant predicted precipitation. Cease operations or postpone planned
operations including movement of vehicles or equipment during precipitation conditions
that may combine with vehicle activity to cause damage to roads, trails, or adjacent land
areas.
Geology - 5: (Mechanical) Plan treatment actions and equipment selection to minimize damage or
alterations to existing soils.
Geology - 6: (Mechanical) Maintain a buffer of 25-50 feet between operations and water bodies or
designated riparian areas. Avoid crossing drainage channels, run-off areas, or dry
streambeds. Install and manage run-off barriers for rainwater in all treatment and
operating areas. Restrict mechanical removal of trees to areas further than 50 feet from
drainage channels.
Geology - 7: (Mechanical) Restrict vehicle traffic to preexisting roads or pre-planned access points
based on equipment size and operations. Limit transport and support equipment to
existing roads. Limit heavy equipment use to slopes less than 30%. Install erosion control
measures on all vehicle roads and traffic areas.
Geology - 8: (Grazing) The City shall conduct grazing operations in a manner that avoids over-grazing
and prevents erosion by appropriately limiting the intensity and scope of grazing. This
mitigation measure shall be implemented through development of a grazing management
plan prepared by a certified range specialist that specifies goals, stocking levels, grazing
periods, installation of range improvements (such as water sources) to evenly distribute
utilization of feed, and monitoring and performance criteria to address the potential
erosion conditions created by over-grazing.
Geology - 9: (Grazing) Develop a site-specific annual grazing plan to be approved by a certified range
specialist that includes project-level plans for sticking, timing, and resource management
goals.
Geology - 10: (Burns) The City shall conduct prescribed burns in a manner that minimizes post-fire
erosion into water bodies and drainage through the use of natural barriers, fire lines along
contours, erosion control barrier deployment, and avoidance of areas with highly erodible
soils. This mitigation measure shall be implemented through development, prior to
conducting a prescribed burn, of a prescribed burn erosion control plan (or included in
the prescribed burn plan) subject to review and approval by City Staff.
Significance after Mitigation: Less Than Significant
Foothills Fire Management Plan Update Page 31 of 46 Mitigated Negative
Declaration
G. HAZARDS AND HAZARDOUS MATERIALS
Note: Some of the thresholds can also be dealt with under a topic heading of Public Health and Safety if the
primary issues are related to a subject other than hazardous material use.
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Create a significant hazard to the public or the
environment through the routing transport, use,
or disposal of hazardous materials?
1, 4
3
b) Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
1, 4
3
c) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
proposed school?
1, 4
3
d) Construct a school on a property that is subject
to hazards from hazardous materials
contamination, emissions or accidental release?
1, 4
3
e) Be located on a site which is included on a list
of hazardous materials sites compiled pursuant
to Government Code Section 65962.5 and, as a
result, would it create a significant hazard to
the public or the environment?
1, 2-Map
N9, 4
3
f) For a project located within an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public airport or
public use airport, would the project result in a
safety hazard for people residing or working in
the project area?
1, 4
3
g) For a project within the vicinity of a private
airstrip, would the project result in a safety
hazard for people residing or working the
project area?
1, 4
3
h) Impair implementation of or physically
interfere with an adopted emergency response
plan or emergency evacuation plan?
1, 2-Map
N7, 4
3
i) Expose people or structures to a significant risk
of loss, injury, or death involving wildland
fires, including where wildlands are adjacent to
urbanized areas or where residences are
intermixed with wildlands?
1, 2-Map
N7, 4
3
j) Create a significant hazard to the public or the
environment from existing hazardous materials
contamination by exposing future occupants or
users of the site to contamination in excess of
soil and ground water cleanup goals developed
for the site?
1, 4
3
Foothills Fire Management Plan Update Page 32 of 46 Mitigated Negative
Declaration
DISCUSSION:
The proposed Plan includes fuel treatment methods (mechanical equipment, prescribed burns, herbicide
application) that could potentially have significant hazardous impacts. The Plan includes mechanical
treatments that require on-site fueling and maintenance, creating a potential for spills and leakage. The
use of mechanical equipment in a high fire danger condition also creates the potential for sparks to ignite
a fire. The use of herbicides could potentially have environmental impacts if strict protocols for use are
not in place or followed. Mitigation measures are provided to reduce impacts from the mechanical and
herbicide uses to a less than significant level. Although the use of prescribed fires to manage fuel could
potentially have impacts, the BAAQMD has strict guidelines that regulate this activity to a less than
significant level of impact. As a Best Management Practice, the City will develop public safety plans to
be executed throughout the prescribed burn cycle, including press and information releases, signs and
notifications, patrols on roads and access points, and development of a fire contingency plan.
Mitigation Measures:
Hazards - 1: All treatment methods involving fueling and maintenance operations shall be strictly
monitored and controlled. This mitigation measure shall be implemented by conducting
all maintenance actions that may produce spills should be executed in areas with
secondary containment protection, away from any water bodies or drainage areas;
cleaning up all spills shall be done on-site, and clean-up materials shall be maintained on
site so they are readily available for use. Inspection of equipment for new leaks and
mechanical problems should be performed daily, prior to operations.
Hazards - 2: Cease actions during periods of high fire danger or during red flag conditions. Ensure that
all mechanical equipment have approved spark arrestors and comply with California
Public Resources Code (PRC) sections 4431, 4435, 4442, and 4437 to limit potential for
ignition of incidental fires.
Hazards - 3: Maintain on-site fire suppression resources to include shovel, water pump, fire
extinguisher, and two-way radio or communications for fire reporting.
Herbicide Application
Hazards - 4: The City shall conduct herbicide application in a manner that uses the least amount of
chemical required to achieve a desired outcome; the herbicide treatment shall be
consistent with the City of Palo Alto’s Integrated Pest Management policy.
Hazards - 5: Provide or confirm adequate training, experience, and oversight to ensure that personnel
are familiar with herbicide operations and planning, site conditions, potential and
identified sensitive resources, and the identification of specific environmental features or
conditions that must be avoided. Herbicide application shall only be applied per a
prescription prepared by a Pesticide Control Advisor licensed in Santa Clara County, and
applied by a licensed Pesticide Control Applicator.
Hazards - 6: The City shall conduct herbicide application in a manner that protects public safety by
informing the public of treatment and restricting access, when deemed appropriate. This
mitigation measure shall be implemented through development of a public safety plan,
which shall include requirements for press and information releases, signs and
Foothills Fire Management Plan Update Page 33 of 46 Mitigated Negative
Declaration
notifications, and guidelines for fencing or area restrictions, and shall be subject to
review and approval of the Pesticide Control Advisor and the Directors of Community
Services and Fire Department, and the terms of which shall be executed throughout the
treatment cycle..
Hazards - 7: The City shall conduct herbicide application in a manner that protects against and
minimizes damage from spills by maintaining strict monitoring and control of operations,
and providing for clean up of all spills to be done on-site, with clean-up materials readily
available for use. This mitigation measure shall be implemented through development of
a spill contingency plan subject to review and approval of the Pesticide Control Advisor
and the Directors of Community Services and Fire Department.
Hazards - 8: Chemical treatments within habitat of California Red-legged Frog shall be conducted
according to U.S. District Court injunction and order covering 66 pesticides (Oct 2006)
and subsequent EPA effects determinations.
Hazards - 9: Clean equipment following actions and prior to movement into new environmental areas.
Hazards - 10: Avoid treating areas adjacent to water bodies, riparian areas, and primary drainage
access. Follow all herbicide labels and directions in determining applications near water
resources or riparian habitats. Limit aerial application to greater than 100 feet from water
resources. Limit ground and hand application to greater than 50 feet.
Hazards - 11: Avoid treating areas used for livestock operations or intended as grazing areas.
Significance after Mitigation: Less Than Significant
H. HYDROLOGY AND WATER QUALITY
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Violate any water quality standards or waste
discharge requirements? 1, 4
3
b) Substantially deplete groundwater supplies or
interfere substantially with groundwater
recharge such that there would be a net deficit
in aquifer volume or a lowering of the local
groundwater table level (e.g., the production
rate of pre-existing nearby wells would drop to
a level which would not support existing land
uses or planned uses for which permits have
been granted)?
1, 2-Map
N2, 4
3
c) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river, in a
manner which would result in substantial
erosion or siltation on- or off-site?
1, 4
3
d) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river, or
substantially increase the rate or amount of
surface runoff in a manner which would result
in flooding on- or off-site?
1, 4
3
Foothills Fire Management Plan Update Page 34 of 46 Mitigated Negative
Declaration
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
e) Create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted
runoff?
1, 4
3
f) Otherwise substantially degrade water quality? 1, 4 3
g) Place housing within a 100-year flood hazard
area as mapped on a federal Flood Hazard
Boundary or Flood Insurance Rate Map or
other flood hazard delineation map?
1, 4
3
h) Place within a 100-year flood hazard area
structures which would impede or redirect
flood flows?
1, 2-Map
N6, 4
3
i) Expose people or structures to a significant risk
of loss, injury or death involve flooding,
including flooding as a result of the failure of a
levee or dam or being located within a 100-year
flood hazard area?
1, 2-
Map-N6,
4
3
j) Inundation by seiche, tsunami, or mudflow?
1, 4
3
k) Result in stream bank instability? 1, 2-Map
N2, 4
3
DISCUSSION:
The potential impacts to water quality are associated with the potential hazards previously identified in
this document related to fuel treatment methods and possible erosion risks. The mitigations that would
address this potential impact to a less than significant level are the same as those listed for the geology
section of this initial study.
Mitigation Measures:
See Geology Mitigation Measures 1-10 and Hazards Mitigation Measures 1, 4-10
Significance after Mitigation: Less Than Significant
I. LAND USE AND PLANNING
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Physically divide an established community? 1, 4 3
b) Conflict with any applicable land use plan,
Foothills Fire Management Plan Update Page 35 of 46 Mitigated Negative
Declaration
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
policy, or regulation of an agency with
jurisdiction over the project (including, but not
limited to the general plan, specific plan, local
coastal program, or zoning ordinance) adopted
for the purpose of avoiding or mitigating an
environmental effect?
1, 2, 4
3
c) Conflict with any applicable habitat
conservation plan or natural community
conservation plan?
1, 2, 4
3
d) Substantially adversely change the type or
intensity of existing or planned land use in the
area?
1, 2, 4
3
e) Be incompatible with adjacent land uses or with
the general character of the surrounding area,
including density and building height?
1, 2, 4
3
f) Conflict with established residential,
recreational, educational, religious, or scientific
uses of an area?
1, 2, 4
3
g) Convert prime farmland, unique farmland, or
farmland of statewide importance (farmland) to
non-agricultural use?
1, 3, 4
3
DISCUSSION:
The proposed Plan does not propose adding or changing the existing land uses of the area and would not
divide any existing community. The project area is not located within a local coastal program, or habitat
conservation plan. Fuel management in the Foothills is compatible with maintaining the health and
safety of the public parks.
Mitigation Measures: None Required
J. MINERAL RESOURCES
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Result in the loss of availability of a known
mineral resource that would be of value to the
region and the residents of the state?
1, 2, 4
3
b) Result in the loss of availability of a locally-
important mineral resource recovery site
delineated on a local general plan, specific plan
or other land use plan?
1, 2, 4
3
Foothills Fire Management Plan Update Page 36 of 46 Mitigated Negative
Declaration
DISCUSSION:
The City of Palo Alto has been classified by the California Department of Conservation (DOC),
Division of Mines and Geology (DMG) as a Mineral Resource Zone 1 (MRZ-1). This designation
signifies that there are no aggregate resources in the area. The DMG has not classified the City for
other resources. There is no indication in the 2010 Comprehensive Plan that there are locally or
regionally valuable mineral resources within the City of Palo Alto.
Mitigation Measures: None Required
K. NOISE
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Exposure of persons to or generation of noise
levels in excess of standards established in the
local general plan or noise ordinance, or
applicable standards of other agencies?
1, 2, 4
3
b) Exposure of persons to or generation of
excessive ground borne vibrations or ground
borne noise levels?
1, 2, 4
3
c) A substantial permanent increase in ambient
noise levels in the project vicinity above levels
existing without the project?
1, 2, 4
3
d) A substantial temporary or periodic increase in
ambient noise levels in the project vicinity
above levels existing without the project?
1, 2, 4
3
e) For a project located within an airport land use
plan or, where such a plan has not been
adopted, would the project expose people
residing or working in the project area to
excessive noise levels?
1, 2, 4
3
f) For a project within the vicinity of a private
airstrip, would the project expose people
residing or working in the project area to
excessive noise levels?
1, 4
3
g) Cause the average 24 hour noise level (Ldn) to
increase by 5.0 decibels (dB) or more in an
existing residential area, even if the Ldn would
remain below 60 dB?
1, 4
3
h) Cause the Ldn to increase by 3.0 dB or more in
an existing residential area, thereby causing the
Ldn in the area to exceed 60 dB?
1, 4
3
i) Cause an increase of 3.0 dB or more in an
existing residential area where the Ldn
currently exceeds 60 dB?
1, 4
3
j) Result in indoor noise levels for residential
development to exceed an Ldn of 45 dB?
1, 4
3
k) Result in instantaneous noise levels of greater
Foothills Fire Management Plan Update Page 37 of 46 Mitigated Negative
Declaration
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
than 50 dB in bedrooms or 55 dB in other
rooms in areas with an exterior Ldn of 60 dB or
greater?
1, 4 3
l) Generate construction noise exceeding the
daytime background Leq at sensitive receptors
by 10 dBA or more?
1, 4
3
DISCUSSION:
The project area is located in the Foothills, where there are limited residential and commercial uses in
proximity to the park perimeter. The proposed fuel treatment methods will occur within open space
areas of the parks and are not anticipated to have any affects on sensitive receptors. The potential noise
sources would emanate from mechanical equipment and grazing goats or sheep, and those would be
temporary in duration.
Mitigation Measures: None Required
L. POPULATION AND HOUSING
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Induce substantial population growth in an
area, either directly (for example, by proposing
new homes and businesses) or indirectly (for
example, through extension of roads or other
infrastructure)?
1, 4
3
b) Displace substantial numbers of existing
housing, necessitating the construction of
replacement housing elsewhere?
1, 4
3
c) Displace substantial numbers of people,
necessitating the construction of replacement
housing elsewhere?
1, 4
3
d) Create a substantial imbalance between
employed residents and jobs?
1, 4 3
e) Cumulatively exceed regional or local
population projections?
1, 4 3
DISCUSSION:
There is no development associated with the Plan; it would not create any new population and housing
impacts for the City. The Plan addresses fuel management in the existing City parks.
Mitigation Measures: None Required
Foothills Fire Management Plan Update Page 38 of 46 Mitigated Negative
Declaration
M. PUBLIC SERVICES
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
Would the project result in substantial adverse
physical impacts associated with the provision of
new or physically altered governmental facilities,
need for new or physically altered governmental
facilities, the construction of which could cause
significant environmental impacts, in order to
maintain acceptable service ratios, response times
or other performance objectives for any of the
public services:
a) Fire protection? 1 3
b) Police protection? 1 3
c) Schools? 1 3
d) Parks? 1 3
e) Other public facilities? 1 3
DISCUSSION:
The implementation of the proposed Plan would not require new public services. There is no development
associated with the Plan; it would not create any new population and housing that would need additional services.
The Plan addresses fuel management in the existing City parks.
Mitigation Measures: None Required
N. RECREATION
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Would the project increase the use of
existing neighborhood and regional parks or
other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated?
1
3
Foothills Fire Management Plan Update Page 39 of 46 Mitigated Negative
Declaration
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
b) Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on the
environment?
1
3
DISCUSSION:
The use of existing recreational facilities would not be impacted by the implementation of the proposed
Plan. The project is designed to enhance fire safety in the parks; it would not generate new users and
does not require new or expanded recreational facilities.
Mitigation Measures: None Required
O. TRANSPORTATION AND TRAFFIC
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Cause an increase in traffic which is
substantial in relation to the existing traffic
load and capacity of the street system (i.e.,
result in a substantial increase in either the
number of vehicle trips, the volume to
capacity ratio on roads, or congestion at
intersections)?
1, 2, 4
3
b) Exceed, either individually or cumulatively,
a level of service standard established by the
county congestion management agency for
designated roads or highways?
1, 4
3
c) Result in change in air traffic patterns,
including either an increase in traffic levels
or a change in location that results in
substantial safety risks?
1, 4
3
d) Substantially increase hazards due to a
design feature (e.g., sharp curves or
dangerous intersections) or incompatible
uses (e.g., farm equipment)?
1, 4
3
e) Result in inadequate emergency access?
1, 4 3
f) Result in inadequate parking capacity? 1, 4 3
g) Conflict with adopted policies, plans, or
programs supporting alternative
transportation (e.g., pedestrian, transit &
bicycle facilities)?
1, 4
3
Foothills Fire Management Plan Update Page 40 of 46 Mitigated Negative
Declaration
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
h) Cause a local (City of Palo Alto) intersection
to deteriorate below Level of Service (LOS)
D and cause an increase in the average
stopped delay for the critical movements by
four seconds or more and the critical
volume/capacity ratio (V/C) value to increase
by 0.01 or more?
1, 4
3
i) Cause a local intersection already operating at
LOS E or F to deteriorate in the average
stopped delay for the critical movements by
four seconds or more?
1, 4
3
j) Cause a regional intersection to deteriorate
from an LOS E or better to LOS F or cause
critical movement delay at such an
intersection already operating at LOS F to
increase by four seconds or more and the
critical V/C value to increase by 0.01 or
more?
1, 4
3
k) Cause a freeway segment to operate at LOS F
or contribute traffic in excess of 1% of
segment capacity to a freeway segment
already operating at LOS F?
1, 4
3
l) Cause any change in traffic that would
increase the Traffic Infusion on Residential
Environment (TIRE) index by 0.1 or more?
1, 4
3
m) Cause queuing impacts based on a
comparative analysis between the design
queue length and the available queue storage
capacity? Queuing impacts include, but are
not limited to, spillback queues at project
access locations; queues at turn lanes at
intersections that block through traffic;
queues at lane drops; queues at one
intersection that extend back to impact other
intersections, and spillback queues on ramps.
1, 4
3
n) Impede the development or function of
planned pedestrian or bicycle facilities?
1, 4 3
o) Impede the operation of a transit system as a
result of congestion?
1, 4 3
p) Create an operational safety hazard? 1, 4 3
DISCUSSION:
The proposed Plan does not create significant numbers of new trips into the Foothills. The activities
required to complete the proposed fuel treatments are temporary in duration and will be spread out over
time; some treatments are proposed annually, while others are proposed every 3-5 years. Thus, it is not
anticipated that the implementation of the Plan would result in a significant traffic impact.
Foothills Fire Management Plan Update Page 41 of 46 Mitigated Negative
Declaration
Mitigation: None Required
P. UTILITIES AND SERVICE SYSTEMS
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Exceed wastewater treatment requirements of
the applicable Regional Water Quality
Control Board?
1, 4
3
b) Require or result in the construction of new
water or wastewater treatment facilities or
expansion of existing facilities, the
construction of which could cause significant
environmental effects?
1, 4
3
c) Require or result in the construction of new
storm water drainage facilities or expansion
of existing facilities, the construction of
which could cause significant environmental
effects?
1, 4
3
d) Have sufficient water supplies available to
serve the project from existing entitlements
and resources, or are new or expanded
entitlements needed?
1, 4
3
e) Result in a determination by the wastewater
treatment provider which serves or may
serve the project that it has inadequate
capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments?
1, 4
3
f) Be served by a landfill with sufficient
permitted capacity to accommodate the
project’s solid waste disposal needs?
1, 4
3
g) Comply with federal, state, and local statutes
and regulations related to solid waste?
1, 4
3
h) Result in a substantial physical deterioration
of a public facility due to increased use as a
result of the project?
1, 4
3
DISCUSSION:
The implementation of the proposed Plan would not require new services. There is no development associated
with the Plan; it would not create any new population and housing that would need additional services. The Plan
addresses fuel management in the existing City parks.
Mitigation Measures: None Required
Foothills Fire Management Plan Update Page 42 of 46 Mitigated Negative
Declaration
Q. MANDATORY FINDINGS OF SIGNIFICANCE
Issues and Supporting Information Resources
Would the project:
Sources Potentially
Significant
Issues
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Does the project have the potential to
degrade the quality of the environment,
substantially reduce the habitat of a fish or
wildlife species, cause a fish or wildlife
population to drop below self-sustaining
levels, threaten to eliminate a plant or animal
community, reduce the number or restrict the
range of a rare or endangered plant or animal
or eliminate important examples of the major
periods of California history or prehistory?
1, 2, 4, 5
3
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
project are considerable when viewed in
connection with the effects of past projects,
the effects of other current projects, and the
effects of probable future projects)?
1, 4,
3
c) Does the project have environmental effects
which will cause substantial adverse effects
on human beings, either directly or
indirectly?
1, 4
3
DISCUSSION:
As detailed in the Biological Resources section of this document, there are potential impacts to sensitive
wildlife species. These impacts can be reduced to levels less than significant. Please refer to the
Biological Resources section of this document for details.
The Foothills Fire Management Plan provides guidelines for fuel management practices in order to
protect lives, enhance the safety of improvements in and around the parks, and to enhance the natural
resource ecosystem health. The proposed fuel treatments all have specific considerations to take into
account when applied. The treatments that potentially have more impacts are regulated by state and local
agencies to ensure proper protocols are followed before implementation. With the oversight of the
regulatory agencies, the project is not anticipated to have substantial adverse effect on humans, wildlife
or plants.
Global Climate Change Impacts
Global climate change is the alteration of the Earth’s weather including its temperature, precipitation,
and wind patterns. Global temperatures are affected by naturally occurring and anthropogenic generated
atmospheric gases, such as carbon dioxide, methane, and nitrous oxide. These gases allow sunlight into
the Earth’s atmosphere, but prevent radiative heat from escaping into outer space, which is known as the
“greenhouse” effect. The world’s leading climate scientists have reached consensus that global climate
change is underway and is very likely caused by humans. Agencies at the international, national, state,
Foothills Fire Management Plan Update Page 43 of 46 Mitigated Negative
Declaration
and local levels are considering strategies to control emissions of gases that contribute to global
warming. There is no comprehensive strategy that is being implemented on a global scale that addresses
climate change; however, pursuant to Senate Bill 97 the Governor’s Office of Planning and Research
(OPR) is in the process of developing CEQA guidelines “for the mitigation of greenhouse gas emissions
or the effects of greenhouse gas emissions.” OPR is required to “prepare, develop, and transmit” the
guidelines to the Resources Agency on or before July 1, 2009. The Resources Agency must certify and
adopt the guidelines on or before January 1, 2010.
Assembly Bill 32 requires achievement by 2020 of a statewide greenhouse gas emissions limit
equivalent to 1990 emissions, and the adoption of rules and regulations to achieve the maximum
technologically feasible and cost-effective greenhouse gas emissions reductions. By 2050, the state plans
to reduce emissions to 80 percent below 1990 levels. While the state of California has established
programs to reduce greenhouse gas emissions, there are no established standards for gauging the
significance of greenhouse gas emissions; these standards are required to be in place by 2012. Neither
CEQA nor the CEQA Guidelines provide any methodology for analysis of greenhouse gases.
To determine whether the proposed project would have a significant impact on global climate change is
speculative, particularly given the fact that there are no existing numerical thresholds to determine an
impact. However, in an effort to make a good faith effort at disclosing environmental impacts and to
conform with the CEQA Guidelines [§16064(b)], it is the City’s position that based on the nature of this
project with its nominal increase in greenhouse gas emissions, the proposed project would not impede
the state’s ability to reach the emission reduction limits/standards set forth by the State of California by
Executive Order S-3-05 and AB 32. For these reasons, this project would not make a cumulatively
considerable contribution to global climate change associated with greenhouse gas emissions.
Foothills Fire Management Plan Update Page 44 of 46 Mitigated Negative
Declaration
SOURCE REFERENCES
1. Project Planner’s knowledge of the site and the proposed project
2. Palo Alto Comprehensive Plan 1998-2010
3. Palo Alto Municipal Code, Title 18 – Zoning Ordinance
4. Palo Alto Foothills Fire Management Plan Update, prepared by Wildland Resource Management,
Inc., January 15, 2009
5. Biological Impact Assessment; Foothills Fire Management Plan, prepared by TRA Environmental
Sciences, Inc., January 8, 2009
Foothills Fire Management Plan Update Page 45 of 46 Mitigated Negative
Declaration
DETERMINATION
On ,the basis of this initial evaluation:
I find that the proposed project COULD NOT have a significant effect on the
environment, and a NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the
environment, there will not be a significant effect in this case because revisions in the
project have been made by or agreed to by the project proponent. A MITIGATED
NEGATIVE DECLARATION will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a "potentially significant impact" or
"potentially significant unless mitigated" impact on the environment, but at least one
effect: 1) has been adequately analyzed in an earlier document pursuant to applicable legal
standards, and 2) has been addressed by mitigation measures based on the earlier analysis
as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required,
but it must analyze only the effects that remain to be addressed.
I find that although ~he proposed project could have a significant effect on the
environment, because all potentially significant effects (a) have been analyzed adequately
in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and
(b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE
DECLARA TION, including revisions or mitigation measures that are imposed upon the
proposed project, nothing further is required.
Foothills Fire Management Plan Update
Declaration
Page 46 of46 Mitigated Negative
Biological Impact Assessment
Foothills Fire Management Plan
Palo Alto, California
January 8, 2009
Prepared for
The City of Palo Alto
Prepared by
TRA Environmental Sciences, Inc.
Menlo Park, California
Biological Impact Assessment
Foothills Fire Management Plan
Palo Alto, California
January 8, 2009
Prepared for
City of Palo Alto
Clare Campbell, Planning
Prepared by
TRA Environmental Sciences, Inc.
545 Middlefield Road, Suite 200
Menlo Park, California 94025
Foothills Fire Management Plan Biological Impact Assessment Page i
TRA Environmental Sciences 1/8/2009
TABLE OF CONTENTS
1.0 Project Location .................................................................................................................. 1
Summary of the Foothills Fire Management Plan .......................................................................... 5
1.1. Treatment Types ............................................................................................................. 5
1.1.1. Defensible Space..................................................................................................... 5
1.1.2. Ignition Prevention.................................................................................................. 6
1.1.3. Containment............................................................................................................ 6
1.1.4. Evacuation............................................................................................................... 7
1.1.5. Firefighter Safety Zones ......................................................................................... 8
1.1.6. Eucalyptus Trees..................................................................................................... 8
1.2. Treatments in Foothills Park........................................................................................... 8
1.2.1. Entry gate, Boronda Lake, and main park road from the entry gate to Shady Cove
picnic area (F.D1, F.E2).......................................................................................................... 8
1.2.2. Shady Cove, Encinal, Pine Gulch and Orchard Glen picnic areas and the main
park road from Shady Cove to the Interpretive Center (F.I1, F.I2, F.I3, F.I4, F.D3, F.E2)... 9
1.2.3. Las Trampas Valley, including the main park road, the interpretive center, the
Oak Grove group picnic area, the maintenance complex and a restroom associated with the
picnic area, and the road from the interpretive center to the Hewlett property (F.E2, F.D4,
F.I5, F.D5, F.E3)................................................................................................................... 12
1.2.4. Treatment areas in the northeast part of Foothills Park including an evacuation
route from Boronda Lake to Alexis Drive, Fire Station 8, Boronda Water Tank, and two
containment sites (F.E4, F.D2, F.D8, F.C4, F.C5)............................................................... 13
1.2.5. Wild Horse Valley (F.E5, F.I6, F.D6).................................................................. 13
1.2.6. Trappers Trail, Pony Tracks, Valley View and Firefighter Safety Zones on
Trappers Trail........................................................................................................................ 14
1.3. Treatments in Pearson-Arastradero Preserve................................................................ 14
1.3.1. Gateway Facility and portions of the preserve northeast of Arastradero Road
(A.D1, A.D2, A.C1, A.C2, A.C3 .......................................................................................... 14
1.3.2. Main part of the Preserve, southwest of Arastradero Road (A.C4, A.C5, A.C6,
A.C7, A.C8, A.C9, A.C10, A.C11, A.C12, A.C13, A.C14, A.C15, A.Rx1, A.Rx2, A.D3,
and A.D4).............................................................................................................................. 14
1.4. Evacuation Routes ........................................................................................................ 15
1.4.1. Arastradero Road (PA.2, AE.1)............................................................................ 15
1.4.2. Page Mill Road (PA.1).......................................................................................... 16
1.4.3. Skyline Boulevard (PA.4)..................................................................................... 16
1.4.4. Los Trancos Road ................................................................................................. 16
2.0 Federal, State and Local Biological Regulations.............................................................. 16
2.1. Introduction................................................................................................................... 16
2.2. Federal........................................................................................................................... 17
2.2.1. Endangered Species Act (ESA)............................................................................ 17
2.2.2. Migratory Bird Treaty Act (MBTA)..................................................................... 17
2.2.3. Bald and Golden Eagle Protection Act ................................................................. 18
2.2.4. Clean Water Act.................................................................................................... 18
2.3. State............................................................................................................................... 19
2.3.1. California Environmental Quality Act (CEQA)................................................... 19
2.3.2. California Endangered Species Act (CESA)........................................................ 20
2.3.3. California Fish and Game Code............................................................................ 21
2.3.4. State Water Resources Control Board/Regional Water Quality Control Board... 21
Foothills Fire Management Plan Biological Impact Assessment Page ii
TRA Environmental Sciences 1/8/2009
2.4. City of Palo Alto ........................................................................................................... 22
3.0 Biological Setting.............................................................................................................. 23
3.1. Vegetation Communities .............................................................................................. 23
3.2. Special-status Species ................................................................................................... 25
3.3. Erosive Soils ................................................................................................................. 34
3.4. Invasive Plant Species................................................................................................... 35
4.0 Impacts.............................................................................................................................. 36
5.0 Mitigation.......................................................................................................................... 40
5.1. Best Management Practices Included in the Palo Alto Foothills Fire Management Plan
Update 40
5.2. Additional Biological Mitigation Measures or Modifications to BMPs....................... 43
6.0 Response to CEQA Checklist Biology Questions ............................................................ 44
7.0 References......................................................................................................................... 47
Appendix A. Tables......................................................................................................................49
LIST OF TABLES
Table 2-1 Potential Special-status Species of Foothills Park and Pearson-Arastradero Preserve 20
Table 3-1 Soil Types in the Palo Alto Foothills Area................................................................... 34
LIST OF FIGURES
Figure 1 Project Location................................................................................................................ 2
Figure 2 Foothills Fire Plan Area, Part A ....................................................................................... 3
Figure 3 Foothills Fire Plan Area, Part B ....................................................................................... 4
Figure 4 Proposed Treatment Locations in Pearson-Arastradero Preserve .................................. 10
Figure 5 Proposed Treatment Locations in Foothills Park ........................................................... 11
Foothills Fire Management Plan Biological Impact Assessment Page 1
TRA Environmental Sciences 1/8/2009
1.0 Project Location
The Palo Alto Foothills Fire Management Plan Update addresses fire management on city-owned
property in the foothills area of the City of Palo Alto (Figures 1, 2, and 3). The foothills area
extends from Foothill Expressway/Junipero Serra Boulevard to Skyline Boulevard. In general
the area contains a mixture of urban, rural and open space lands. The Palo Alto Foothills Fire
Management Plan Update prescribes vegetation management in two city-owned open space
areas, Foothills Park and Pearson-Arastradero Preserve, and on evacuation routes within city
limits along Arastradero Road, Page Mill Road, Los Trancos Road, and Skyline Boulevard.
Pearson-Arastradero Preserve is located on Arastradero Road between Page Mill Road and
Alpine Road. Foothills Park is located on Page Mill Road, and is contiguous with Pearson-
Arastradero Preserve.
Foothills Fire Management Plan Biological Impact Assessment Page 2
TRA Environmental Sciences 1/8/2009
Figure 1 Project Location
... Pearson-Arastradero Preserve * Foothills Park
Source: StreeMap USA Data
Map: TRA, December 2008
\ r .. _ .. _' ,
. _; -'z:'i!:"
"'/.
i '. ,
'"r",
!
I
.'
:-, -./
N o 7,000 14,000 28,000 /I. .............. oc=============o·, Feet ~
•
Foothills Fire Management Plan Biological Impact Assessment Page 3
TRA Environmental Sciences 1/8/2009
Figure 2 Foothills Fire Plan Area, Part A
•
* •••
Pearson-Ara stradero Preserve
Foothills Park
~""""""~""""""-============================iFeet E"acuation Routes 0 3,250 6,500 13,000
Source: California Spatial Information Library { CaSIL)
Map: TRA, December 2008
N
A
Foothills Fire Management Plan Biological Impact Assessment Page 4
TRA Environmental Sciences 1/8/2009
Figure 3 Foothills Fire Plan Area, Part B
* Foothills Park
• •• Evacuation Routes
~""""~~~""""~~;====================="',iFeet o 2,700 5.400 10.800
Source: California Spatial Information Library ( CaSIL)
Map: TRA, December 2008
N
A
Foothills Fire Management Plan Biological Impact Assessment Page 5
TRA Environmental Sciences 1/8/2009
Summary of the Foothills Fire Management Plan
The City of Palo Alto has updated an existing fire management plan to address vegetation,
ignition prevention, defensible space and evacuation routes on city-owned land in the foothills.
The area addressed in the plan includes Foothills Park and Pearson-Arastradero Preserve, as well
as evacuation routes along Page Mill Road, Los Trancos Road, Arastradero Road, and Skyline
Boulevard within city limits.
Currently, the City uses mowing, discing, hand labor (to trim trees and shrubs) and grazing
(sheep/goats) to reduce fuel loads and provide fire breaks in the Park and Preserve. The updated
fire management plan includes hand labor (weed-whipping, trimming with saws), grazing, and
mowing, and introduces prescribed burning in Pearson-Arastradero Preserve. It converts most of
what is currently disced to being mowed or grazed instead. It also introduces vegetation
trimming within 30 feet of the roadway edge along three major evacuation routes, and requires
coordination with neighboring jurisdictions. It recommends that grasses be trimmed after they
have cured (i.e., summer), and that pruning occur between November and April when the chance
of insect infestation is lower (at least for pines and eucalyptus). The plan also recommends that
areas infested with invasive species not be trimmed at seed set in order to reduce the amount of
seed that is spread around by management activities.
1.1. Treatment Types
The updated fire management plan is organized according to treatment type, and includes four
treatment types, called 1. Defensible Space, 2. Ignition Prevention, 3. Containment, 4.
Evacuation, 5. Firefighter Safety Zones, and 6. Eucalyptus. It also specifies locations where the
treatments would be applied. The treatment types are summarized as follows, and the locations
are described in sections 2.2 and 2.3 further below.
1.1.1. Defensible Space
These activities apply to areas around structures and critical infrastructure, including entry gates,
interpretive centers, restrooms, maintenance, water tanks, and pump stations. They entail cutting
and removing vegetation within 100 feet of the structure. The method depends on the vegetation
type.
Grassland will be weed-whipped or mowed to a height of 4 inches or less.
All dead plant material within 100 feet of the structure will be removed, including dead leaves,
needles, plant debris, loose papery bark, and dead branches within live ground covers, vines, and
shrubs.
In the woodland branches smaller than 3 inches in diameter within 8 feet of the ground will be
removed. Plants will also be removed as necessary to break vertical continuity between ground
covers, shrubs, trees and structures. The duff will be maintained no deeper than 3 inches. All
trees bigger than 8 inches in diameter will be left, and at least one-third of the trees less than 8
inches in diameter will be left to retain a range of size categories and species. In heavily wooded
areas the trees may be thinned to a density of less than 50 trees per acre, however the structure of
the remaining woodland is more important than the absolute density of the trees (C. Rice, pers.
comm.). The structure should prevent shrubs from transferring fire from the ground up into the
Foothills Fire Management Plan Biological Impact Assessment Page 6
TRA Environmental Sciences 1/8/2009
canopy of the trees. It is also important to keep the tree canopy dense enough to prevent or
hinder the growth of shrubs in the understory.
The work will be done with hand labor, grazing, and mowing. The work will be done annually
in grassland and 3 to 10 years in woodland, coastal scrub, and chaparral. Some defensible space
work is currently done at the interpretive center and Fire Station 8 in Foothills Park, and at the
Gateway Facility in Pearson-Arastradero Preserve.
1.1.2. Ignition Prevention
These activities apply to barbeque sites in 6 picnic areas in Foothills Park. A ten-foot radius
around each barbeque will be raked to bare earth. In addition, the area within 30 feet of each
barbeque will be trimmed and thinned as defined for Defensible Space. All of the barbeque sites
are in woodland. The treatment will be done with hand labor to treat grasses and downed debris
on an annual basis, and to trim trees and shrubs as necessary every 3 to 5 years. The trimming
and raking work within 30 feet of each barbeque would be a new activity.
No ignition prevention management is proposed for Pearson-Arastradero Preserve in the plan,
however, the City of Palo Alto Utilities Department maintains a power line along Arastradero
Creek in the preserve which is a possible ignition source. The Utilities Department clears
vegetation around each pole annually, and this is expected to continue.
1.1.3. Containment
These activities are intended to compartmentalize fuels so it is easier to contain and control a
fire. Several methods are used. In Foothills Park, a series of fuel breaks will be maintained in
grassland, coastal scrub and chaparral. These breaks border existing graded roads along
Trappers Trail, Pony Tracks Trail, and Valley View Fire Trail. In addition, two areas northeast
of the entry gate will be mowed or grazed; one is at Bobcat Point, and the other is on the slope
adjacent to homes on Altamont Circle. No treatments are specified for Shotgun, Madrone or
Charley Brown fire roads in this update. These fire breaks will only be maintained as service
roads in the future, including roadside grass mowing and grading to prevent erosion (as in the
past). The brush and tree trimming done in the past will not be done unless it is required to clear
the road.
The roads are graded annually for access (not just for fire). Trappers Trail is currently mowed
annually for a distance of 100 to 200 feet from the road. The Fire Management Plan Update
proposes to reduce the area of annual mowing along Trappers Trail from 100-200 feet to 10-30
feet. The remaining area that has been mowed in the past will be mowed every three years (two
years rest, one year mow), in order to encourage a grassland with no more than 30 percent cover
of shrubs to grow in this area. The reason this break is so wide is that it is located at the top of a
long slope of chaparral, and a fire in the chaparral could have very long flame lengths. A larger
break is needed in order to be able to fight a fire in the chaparral and to provide for firefighter
safety (C. Rice, pers. comm.).
The treatment along the Pony Tracks Trail and the Valley View Fire Trail is to annually mow ten
feet on either side of the road, and every three years to mow to the topographic break in slope
(about 50 feet from the road), with the intent of maintaining a brush cover of 30 percent or less.
These trails are currently mowed in this manner.
Foothills Fire Management Plan Biological Impact Assessment Page 7
TRA Environmental Sciences 1/8/2009
In Pearson-Arastradero Preserve, containment entails mowing a ten-foot wide swath of grassland
around the perimeter of the preserve within 15 to 45 feet of the park boundary, grazing where
coastal scrub, woodland or chaparral are near homes, mowing grassland along selected trails for
a width of 10 feet on either side of the trail, mowing/grazing 48.7 acres of grassland northeast of
Arastradero Road, and prescribed burning/grazing in 42.7 acres of grassland southwest of
Arastradero Road. The grassland treatments would occur annually, and the scrub, woodland and
chaparral treatments would occur every 3 to 5 years. A strip that is currently disced near the
Preserve border at Liddicoat Circle would continue to be disced annually if grazing has not
created a fuel-free zone (C. Rice, pers. comm.). An area near the Preserve border at Paseo del
Roble Drive would change from being disced to being grazed. Currently the perimeter and a
center ridge are disced, so the Fire Management Plan Update would reduce the area that is disced
and would introduce grazing and prescribed burning. A total area of about 43 acres would be
burned. The treatment along the road that borders Arastradero Creek would include mowing for
fifteen feet on the grassland side of the road and selective hand treatment of vegetation on the
creek side of the road.
1.1.4. Evacuation
These treatments are intended to reduce fire intensity next to roads to allow firefighting vehicles
to pass and to ensure safe passage to people trying to reach safety zones or leave the area. The
treatment extends 30 feet out from each roadway edge along the primary evacuation routes, and
15 feet from one edge of the secondary evacuation route. The riparian vegetation along Buckeye
Creek, which borders one side of the secondary evacuation route, is dominated by coyote brush.
This vegetation will be treated consistent with riparian treatments near Arastradero Creek in
order to maintain creek bank stability. Some dead material will be removed from the top of the
creek bank, but no work would occur in the creek channel.
The treatment methods include mowing, grazing and hand labor and occur in grassland,
woodland, and coastal scrub. Grassland would be mowed or grazed annually to a height of 4
inches or less for ten feet from the road edge. Woodland would be grazed or would be trimmed
by hand so that branches smaller than 3 inches in diameter within 8 feet of the ground are
removed. Plants will also be trimmed as necessary to break vertical continuity between ground
covers, shrubs, trees and structures. The duff will be maintained no deeper than 3 inches. All
trees bigger than 8 inches in diameter will be left, and at least one-third of the trees less than 8
inches in diameter will be left to retain a range of size categories and species. Remove only
those small trees that could enable a fire to extend to the tree canopy. In heavily wooded areas
the trees may be thinned to a density of less than 50 trees per acre, however the structure of the
woodland is more important than the density, with the goal of preventing fire from extending
from the ground through shrubs or vines into the canopy (Carol Rice, pers. comm.). As currently
required by fire code, a vertical clearance of 13.5 feet will be maintained over the roadbed. This
clearance is mostly already in place.
Within Foothills Park the primary evacuation routes are the park road that extends from the entry
gate around Boronda Lake and through Las Trampas Valley to the maintenance facility, the road
from Boronda Lake to Alexis Drive in the northeast part of the park, and the road from the
Interpretive Center to the Hewlett property in the northwest part of the park. There is a
secondary evacuation route in Wild Horse Valley that extends from the Towle Campground to
the main park road.
Foothills Fire Management Plan Biological Impact Assessment Page 8
TRA Environmental Sciences 1/8/2009
Other primary evacuation routes include Arastradero Road from Page Mill Road to the city limit,
Page Mill Road from Arastradero Road to Skyline Boulevard, and portions of Skyline Boulevard
within city limits. The evacuation routes are not currently treated on city-owned land, so these
treatments would be new.
1.1.5. Firefighter Safety Zones
These treatments provide areas where firefighters can find refuge during a fire event. Four
firefighter safety zones are proposed along the Trappers Trail fuel break in Foothills Park. These
areas have a 100-ft radius and are mowed or grazed annually. The treatment will affect about 4
acres of grassland/coastal scrub, and occurs in areas along Trappers Trail that are currently
mowed annually.
1.1.6. Eucalyptus Trees
The Fire Management Plan provides direction for trimming or removal of eucalyptus trees, but
does not specify any particular trees for removal. The Fire Management Plan identifies that
raptors may use eucalyptus trees as perches and nesting sites, and that replacement perches or
nesting platforms can be installed prior to removal of the trees.
The existing and planned activities are summarized below. They are organized by general area,
and explain how the specific treatments would be applied within those areas. The treatment
locations are shown on Figures 4 and 5.
1.2. Treatments in Foothills Park
1.2.1. Entry gate, Boronda Lake, and main park road from the entry gate to Shady Cove
picnic area (F.D1, F.E2)
This area includes a structure (the entry gate) and a major evacuation route (the main park road),
that are subject to the measures required for Defensible Space and Evacuation. Treatments will
be completed within 100 feet of the entry gate, and extend 30 feet from either edge of the
roadway.
The entry gate is surrounded by pavement, but the 100 foot distance extends into grassland and
woodland. Under this treatment prescription, the grassland within 30 feet of the structure would
be weed-whipped, the pavement would be cleared of leaves or other flammable debris, and the
woodland would be trimmed. Trimming in the woodland would be done by hand, with the goal
of reducing the chances that a fire started in the understory could extend into the tree canopy.
This generally means removing branches smaller than 3 inches in diameter within 8 feet of the
ground and trimming or removing understory plants as necessary to break vertical continuity
between ground covers, shrubs, trees and structures. These measures would be new. A 20-foot
clearance is mowed around the restroom near the entry gate approximately every other year.
This restroom is in woodland, and the treatment area would extend out 100 feet from the
structure.
The evacuation route is bordered by primarily grassland, some woodland, a small patch of
chaparral, and Boronda Lake. The grassland would be mowed, grazed or weed-whipped within
Foothills Fire Management Plan Biological Impact Assessment Page 9
TRA Environmental Sciences 1/8/2009
10 feet of a structure annually to achieve a height of 4 inches or less. The grassland is dominated
by non-native annual grasses, so specific measures for native grasses are not necessary. The
woodland would be trimmed as described above for the entry gate. The chaparral is on a roadcut
and would be left in place to prevent erosion. These measures would mostly be new; a seven-
foot swath of grassland is mowed along the roadside from the entrance gate to Vista hill, and
every two years trees along the main park road are trimmed for tall vehicle clearance.
1.2.2. Shady Cove, Encinal, Pine Gulch and Orchard Glen picnic areas and the main park
road from Shady Cove to the Interpretive Center (F.I1, F.I2, F.I3, F.I4, F.D3, F.E2)
These picnic areas contain barbeques that will be treated for ignition prevention. There is also a
restroom that will be treated as defensible space. The area around each barbeque would be
completely cleared for a ten foot radius, then the woodland vegetation would be trimmed by
hand out to a 30 foot radius to remove all dead material and live branches smaller than 3 inches
in diameter below 8 feet, and to remove understory plants as necessary to break vertical
continuity between ground covers, shrubs, trees and structures. The area around the restroom is
woodland, which would be trimmed in the same way but for a radius of 100 feet rather than 30
feet. The main park road in this area is bordered by woodland and grassland with shrubs (along
the dam). This vegetation would be subject to mowing/grazing and hand labor for a distance of
30 feet from either side of the road. The grasses would be treated annually and the woodland
would be treated every 3 to 5 years. Past efforts in these areas have included grazing with goats
near the picnic areas, mowing a 20-foot clearance around the Orchard Glen picnic area, roadside
tree trimming every 2 to 5 years for large/tall vehicle clearance. Trimming 30 feet out from the
edge of the road and from the barbeques would be new.
Foothills Fire Management Plan Biological Impact Assessment Page 10
TRA Environmental Sciences 1/8/2009
Figure 4 Proposed Treatment Locations in Pearson-Arastradero Preserve
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Foothills Fire Management Plan Biological Impact Assessment Page 11
TRA Environmental Sciences 1/8/2009
Figure 5 Proposed Treatment Locations in Foothills Park
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Foothills Fire Management Plan Biological Impact Assessment Page 12
TRA Environmental Sciences 1/8/2009
1.2.3. Las Trampas Valley, including the main park road, the interpretive center, the Oak
Grove group picnic area, the maintenance complex and a restroom associated with the
picnic area, and the road from the interpretive center to the Hewlett property (F.E2,
F.D4, F.I5, F.D5, F.E3)
This area will be treated for evacuation, defensible space and ignition prevention. The main park
road is bordered on one side by an irrigated meadow, and on the other by grassland and
woodland. The treatments would occur in the grassland and woodland, and would include
mowing, grazing and hand labor within 10 feet of the road edge to keep the grass at 4 inches or
less in height, and to remove branches smaller than 3 inches in diameter within 8 feet of the
ground, and remove understory plants as necessary to break vertical continuity between ground
covers, shrubs, trees and structures. Currently in this area the grassland along the road is mowed
in a 4-ft width annually, the parking between the Interpretive Center and the Oak Grove group
picnic area is mowed/weed-whipped around the roadside boulders for aesthetics, there is
occasional tree trimming (2-4 year cycle) to limb up for visual/patrol needs and vehicle
clearance, and the trees in the parking areas are trimmed for the same reasons along with hazard
tree prevention.
The Oak Grove group picnic area contains a barbeque. The area within 10 feet of the barbeque
will be raked clean annually, and vegetation within 30 feet of the barbeque will be kept clean of
dead debris, the trees will be limbed up 8 feet from the ground, and the understory plants will be
removed as necessary to prevent spread of a fire from the ground into the canopy of the trees.
Vegetation trimming would be done by hand, and would likely be necessary every three to five
years. Currently the grasses in the barbeque area are mowed or weed-whipped, the leaves are
raked annually around the large barbeque, and brush and tree limbs are cleared.
The interpretive center, the maintenance complex, and the restroom associated with the Oak
Grove group picnic area will be treated as defensible space. These buildings are in grassland and
woodland. Grass within 30 feet of these buildings will be mowed, grazed, or weed-whipped to
keep the grasses at less than four inches in height. Woodland vegetation within 100 feet of these
buildings will be mowed, grazed, or trimmed by hand to remove dead debris, to remove branches
3 inches in diameter or less up to 8 feet from the ground, and to remove understory plants that
can spread fire from the ground into the canopy. This will be done annually, although the
trimming may only be necessary every 3 to 5 years. Currently the vegetation is trimmed to
provide defensible space immediately around the buildings, to about 30 feet; this would extend
the treated area to 100 feet.
The one-way road that leads from the back of the interpretive center uphill to the Hewlett
Property and the edge of Pearson-Arastradero Preserve is in grassland and woodland. Grass
within 30 feet of the roadway edge will be mowed or weed-whipped to keep the grasses at less
than four inches in height. Other vegetation will be mowed or trimmed by hand to remove dead
debris, to remove branches 3 inches in diameter or less up 8 feet from the ground, and to remove
understory plants that can spread fire from the ground into the tree canopy. The grasses will be
treated annually, and the woodland may only need treatment every 3 to 5 years. Currently the
roadsides are mowed annually with a flail mower, in a swath up to 7 feet wide.
Foothills Fire Management Plan Biological Impact Assessment Page 13
TRA Environmental Sciences 1/8/2009
1.2.4. Treatment areas in the northeast part of Foothills Park including an evacuation route
from Boronda Lake to Alexis Drive, Fire Station 8, Boronda Water Tank, and two
containment sites (F.E4, F.D2, F.D8, F.C4, F.C5)
This area includes grassland, woodland and chaparral vegetation. There are also landscape trees
around Boronda Water Tank. The evacuation route is in grassland and will be mowed, grazed or
weed whipped annually to keep the grass height at 4 inches or less within 10 feet of the edge of
the road. Currently the roadside form Fire Station 8 to Alexis Drive is mowed every 2 to 3 years
in a swath up to 7 feet wide, and portions of the grassland are also disced annually. Roadside
tree trimming also occurs every 2 to 5 years for large/tall vehicle clearance. Under the Fire
Management Plan the mowed area would be increased, the discing would be removed, and tree
trimming would increase to extend 30 feet from the edge of the road, rather than immediately
above the road.
Fire Station 8 and the Boronda Water Tank will be treated as defensible space, which means the
vegetation within 100 feet of the structure will be trimmed. Fire Station 8 is already kept clear of
vegetation within 100 feet. Vegetation around the water tank that will be trimmed includes
woodland, grassland, landscaping, and possibly chaparral. Grazing and hand labor will be used
to keep grasses at 4 inches or less in height, to remove dead branches smaller than 3 inches in
diameter within 8 feet of the ground, and to remove understory plants as necessary to break
vertical continuity between ground covers, shrubs, trees and structures. If it is necessary to
modify the chaparral, the chaparral may be mowed, shortened or, alternatively, plants can be
selectively removed to create shrub islands that are less than 12 feet in diameter (or twice the
height of the tallest shrub, whichever is smaller) and are at least eight feet apart (or twice the
height of the tallest shrub, whichever is greater). Currently the vegetation around the water tank
is not managed, so these activities will be new.
The containment treatments in this portion of the park (F.C4 and F.C5) are located where the
park boundary is adjacent to homes, and include Bobcat Point. The vegetation type is grassland,
woodland, and chaparral. The proposed treatment method is grazing with goats. One area
(F.C5) is currently disced where there is grassland. Grazing with goats would be a new method
in this area and grassland, woodland and chaparral would be newly grazed.
1.2.5. Wild Horse Valley (F.E5, F.I6, F.D6)
Wild Horse Valley has three treatments, including a secondary evacuation route, defensible
space around a pump station, and ignition prevention. The evacuation route is a dirt road that
extends along Buckeye Creek and passes through woodland, grassland and coastal scrub.
Because this is a secondary evacuation route, vegetation within 15 feet of the edge of the road
will be trimmed along one side, and the other side will be left untreated because it is a creek
bank. Treatment methods include mowing, grazing and hand labor. Grasses will be cut to 4
inches or less annually. Woodland will be trimmed so that branches smaller than 3 inches in
diameter within 8 feet of the ground are removed. Understory plants will also be removed as
necessary to break vertical continuity between ground covers, shrubs, trees and structures.
Where it is not in the riparian zone, the coastal scrub will be mowed, or alternatively, plants can
be selectively removed to create shrub islands that are less than 12 feet in diameter (or twice the
height of the tallest shrub, whichever is smaller) and are at least eight feet apart (or twice the
height of the tallest shrub, whichever is greater). Currently the Wild Horse Valley road is
mowed in a 7-foot swath along the edge of the road, and about 5-7 acres of the valley floor are
Foothills Fire Management Plan Biological Impact Assessment Page 14
TRA Environmental Sciences 1/8/2009
mowed to control yellow star thistle and tall grasses. Roadside tree trimming is also done every
2 to 5 years for large/tall vehicle clearance.
The Towle Campground at the upper end of Wild Horse Valley contains barbeques that are a
potential ignition source. The campground is in woodland. The area within 10 feet of the
barbeques will be cleared and raked annually. The area within 30 feet of the barbeques will be
trimmed as for defensible space, which includes removing branches smaller than 3 inches in
diameter within 8 feet of the ground and removing understory plants as necessary to break
vertical continuity between the ground and the tree canopy. Past treatments in this area have
included grazing with goats, mowing/weed whipping of grasses near the barbeques, and some
clearing of brush and tree limbs near the barbeques.
The Boronda Water Tank pump station is also located at the Towle Campground. It is in
woodland. It will be treated as defensible space, which means that the woodland will be trimmed
within 100 feet of the structure so that branches smaller than 3 inches in diameter within 8 feet of
the ground will be removed, dead vegetation is removed, and understory plants that connect
ground cover with the tree canopy, and thus can serve as ladder fuels, are removed. Currently
the woodland in this area is not trimmed, and this work would be new.
1.2.6. Trappers Trail, Pony Tracks, Valley View and Firefighter Safety Zones on Trappers
Trail
The treatments located along Trappers Ridge on the west side of the park include containment
and firefighter safety zones, and have been previously described (see containment, above). The
treatments will occur in grassland and chaparral and are limited to areas that are currently
mowed annually except for small areas to the south that will be treated for the first time.
1.3. Treatments in Pearson-Arastradero Preserve
1.3.1. Gateway Facility and portions of the preserve northeast of Arastradero Road (A.D1,
A.D2, A.C1, A.C2, A.C3
Treatments in this area include defensible space around the Gateway Facility and the restrooms,
and containment treatments in the rest of this side of the Preserve. The vegetation is grassland,
and the treatment methods include mowing or weed-whipping annually to maintain grass height
at 4 inches or less within 100 feet of the Gateway Facility buildings, mowing a 10-ft swath
around the Preserve boundary (or grazing the entire area), grazing the grassland inside the
perimeter area, and discing a 10-ft wide fuel break along the border with Liddicoat Circle.
Currently the vegetation is mowed around the Gateway Facility annually for a distance of 30
feet, and the entire perimeter is disced, including wide swaths adjacent to homes and adjacent to
a eucalyptus wind break on the border with Stanford lands.
1.3.2. Main part of the Preserve, southwest of Arastradero Road (A.C4, A.C5, A.C6, A.C7,
A.C8, A.C9, A.C10, A.C11, A.C12, A.C13, A.C14, A.C15, A.Rx1, A.Rx2, A.D3, and
A.D4)
On the southwest side of Arastradero Road the treatments include containment, prescribed fire,
and defensible space.
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TRA Environmental Sciences 1/8/2009
Containment in this portion of the Preserve is described in detail above, under Containment.
This treatment will affect grassland, woodland, and the riparian corridor along Arastradero Creek
where selective trimming will be done by hand.
Grazing will be used along the preserve boundary with Paseo del Roble (A.C4) rather than
discing because this area contains serpentine soils. The area is currently disced; it cannot be
mowed because the slope is too steep for the mowing equipment.
The defensible space treatment will be used around a pump station and a water tank; these
treatments will affect grassland and woodland, and will be new. Willow riparian vegetation
within 100 feet of the pump station will not be removed, but other vegetation will be.
Currently, discing is done between Gate B (on Arastradero Road about a quarter-mile west of the
Preserve parking lot) along the ridgetop east paralleling the Meadow Lark Trail, from Gate C
(John Marthens Lane) east towards the Corte Madera Water Tank, and from Gate C south
following the perimeter and then east towards Arastradero Creek. This would no longer occur.
Trailside mowing and/or weed whipping is done along all trails in the Preserve annually, and the
width varies from 1 to 4 feet. Under the Fire Management Plan this would be increased to 10
feet, and would be done annually.
Prescribed fire is proposed in two grassland locations in the middle of the Preserve that are
currently mowed or grazed. The burns would occur in late spring or early fall with a resulting
cover of not less than 20%, and would occur no more often than every 3 to 5 years. The intent is
to promote the growth of native plant species. A fall burn is more closely aligned with the
natural fire cycle in California, and several native plant species are likely adapted to such a
regime. Treatment boundaries in these two locations are mowed grassland along trails and the
road along Arastradero Creek. Additional firebreaks for these areas are not required; if
additional “cut-off” places are to be installed, they can be mowed prior to the burn or
implemented using Class A foam. A prescription or burn plan will be prepared prior to this
treatment, which will address fuel reduction requirements, local weather conditions, and
available resources for fire management. This treatment would be new.
1.4. Evacuation Routes
The treatment for evacuation routes is described above under Evacuation.
1.4.1. Arastradero Road (PA.2, AE.1)
The vegetation along Arastradero Road from Page Mill Road to the city limit includes willow
riparian, grassland, coastal scrub, woodland, and eucalyptus. The grassland would be mowed or
weed-whipped within 10 feet of the edge of the pavement. Woodland and coastal scrub within
30 feet of the road edge would be trimmed by hand to remove branches less than 3 inches in
diameter within 8 feet of the ground, remove dead debris, and trim or remove understory plants
to prevent fire from extending up into the tree canopy via the understory. The willow riparian
area along Arastradero Creek would be left untreated. Eucalyptus would either be trimmed and
cleared of loose bark and debris, or would be entirely removed.
Foothills Fire Management Plan Biological Impact Assessment Page 16
TRA Environmental Sciences 1/8/2009
Currently the edge of the roadway is mowed (2-5 feet) annually for motorist and bicyclist sight
clearance and safety.
1.4.2. Page Mill Road (PA.1)
The vegetation along Page Mill Road is dominated by woodland, but also includes some
grassland and chaparral. The woodland and chaparral within 30 feet of either side of the road
would be trimmed by hand to remove branches less than 3 inches in diameter within 8 feet of the
ground, and understory plants would be trimmed or removed to prevent spread of fire into the
canopy. Dead vegetation and debris would also be removed. The chaparral could also be
mowed or cut into islands at least eight feet apart. Grassland within 10 feet of the road would be
kept at a height of 4 inches or less. Treatment methods could include hand labor, mowing, and
grazing.
Currently approximately 3.5 to five miles of Page Mill Road is mowed 2 to 5 feet from the road
edge, and PG&E trims vegetation to keep utility lines clear.
1.4.3. Skyline Boulevard (PA.4)
The vegetation along the portions of Skyline Boulevard that are in the city limits includes
grassland, woodland, and a small amount of chaparral. These areas would be treated as
described for Page Mill Road, above. These treatments would be new.
1.4.4. Los Trancos Road
Los Trancos Road is located along the jurisdictional boundaries between Portola Valley, Palo
Alto, and Santa Clara County, and treatment along this corridor will be coordinated between the
jurisdictions. Vegetation within 30 feet of the edge of the roadway will be treated using mowing,
grazing and hand labor, as described under Evacuation, above. These treatments would be new.
2.0 Federal, State and Local Biological Regulations
2.1. Introduction
Biological resources in California are protected under federal and state laws. The laws that
pertain to the biological resources found in Foothills Park and Pearson-Arastradero Preserve
include the:
• U.S. Endangered Species Act (protecting species listed by the federal government as
threatened or endangered);
• U.S. Clean Water Act (protecting water quality and wetland habitat).
• U.S. Migratory Bird Treaty Act (protecting most U.S. birds);
• U.S. Bald and Golden Eagle Protection Act (protecting these eagles);
• California Environmental Quality Act (mitigating the environmental effects of human-
initiated development);
• California Endangered Species Act (protecting species listed by the state as rare,
threatened, or endangered under Fish and Game Code 2050 et seq);
Foothills Fire Management Plan Biological Impact Assessment Page 17
TRA Environmental Sciences 1/8/2009
• California Department of Fish and Game Code (Sections 1600-1607 that protect stream
bed, bank and channel; 3500-3516 that protect nesting birds and fully-protected birds;
4700 and 5050 that protect fully-protected mammals, reptiles and amphibians).
In addition, the City of Palo Alto has a tree preservation ordinance and municipal code that
governs open space districts.
2.2. Federal
2.2.1. Endangered Species Act (ESA)
The United States Endangered Species Act (ESA) is administered by the United States Fish and
Wildlife Service (USFWS for all species but fish and NOAA Fisheries for fish species). The
federal ESA provides protection for species included on the endangered species list (known as
“listed species”). In particular, the federal act prohibits "take". "Take" is defined by the ESA as
"to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect a federally listed,
endangered species of wildlife, or to attempt to engage in any such conduct." Federal regulations
also define take to include the incidental destruction of animals in the course of an otherwise
lawful activity, such as habitat loss due to development. Under those rules the definition of take
includes significant habitat modification or degradation that actually kills or injures wildlife by
significantly impairing essential behavioral patterns, including breeding, feeding, or shelter (50
CFR Section 17.3).
Take may be allowed under a permit by either Section 7 or Section 10(a) of the ESA. The permit
is issued under Section 7 if another federal agency funds or issues a permit for the project (U.S.
Army Corps of Engineers for example). The permit is issued under Section 10(a) if there is no
federal involvement in the project.
The federally listed species protected by the ESA that have been documented to occur in
Foothills and Pearson/Arastradero Parks or adjacent areas are the California red-legged frog
(Rana aurora draytonii), California tiger salamander (Ambystoma californiense), steelhead
(Oncorhynchus mykiss irideus), Bay checkerspot butterfly (Euphydryas editha bayensis), Marin
western flax (Hesperolinon congestum), San Mateo thornmint (Acanthomintha duttonii), and San
Mateo woolly sunflower (Eriophyllum latilobum). The habitats of these species include creeks,
ponds, wetlands and adjacent upland habitat, and serpentine soils. The governing agency is the
U.S. Fish and Wildlife Service, except for steelhead, which is addressed by NOAA Fisheries.
2.2.2. Migratory Bird Treaty Act (MBTA)
The Migratory Bird Treaty Act implements various treaties and conventions between the U.S.
and Canada, Japan, Mexico and the former Soviet Union for the protection of migratory birds.
Unless permitted by regulations, the Act provides that it is unlawful to pursue, hunt, take, capture
or kill; attempt to take, capture or kill; possess, offer to or sell, barter, purchase, deliver or cause
to be shipped, exported, imported, transported, carried or received any migratory bird, part, nest,
egg or product, manufactured or not.
In short, under the MBTA it is illegal to remove vegetation containing nests that are in active
use, since this could result in killing a bird or destroying an egg. This would also be a violation
of CDFG code (see section 3.3.3, below).
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2.2.3. Bald and Golden Eagle Protection Act
Under the Bald and Golden Eagle Protection Act it is unlawful to import, export, take, sell,
purchase, or barter any bald eagle or golden eagle, or their parts, products, nests, or eggs.
“Take” includes pursuing, shooting, poisoning, wounding, killing, capturing, trapping,
collecting, molesting, or disturbing. Exceptions may be granted by the USFWS for scientific or
exhibition use, and for cultural use by Native Americans. However, no permits may be issued
for import, export, or commercial activities involving eagles.
2.2.4. Clean Water Act
The Federal Clean Water Act (CWA) is the primary federal law regulating water quality. The
implementation of the Clean Water Act is the responsibility of the U.S. Environmental
Protection Agency. That agency depends on other agencies, such as the individual states and the
U.S. Army Corps of Engineers (USACE), to assist in implementing the Act. The objective of the
Clean Water Act is to “restore and maintain the chemical, physical, and biological integrity of
the Nation’s waters”. Section 401 and 404 apply to project activities that would impact waters of
the U.S. (creeks, ponds, wetlands, etc). The California State Water Resources Control Board
enforces section 401 of the Clean Water Act (see below) and the USACE enforces Section 404.
Clean Water Act, Section 401: Any applicant for a Federal permit to impact waters of the U.S.
under Section 404 of the Clean Water Act, including Nationwide permits (NWP) where pre-
construction notification is required, must also provide to the U.S. Army Corps of Engineers a
certification from the State of California. The “401 Certification” is provided by the State Water
Resources Control Board through the local Regional Water Quality Control Board.
The Regional Water Quality Control Board (RWQCB) recommends the application be made at
the same time that any applications are provided to other agencies, such as the U.S. Army Corps
of Engineers, the U.S. Fish and Wildlife Service, or NOAA Fisheries. Application is not final
until completion of environmental review under the California Environmental Quality Act (i.e.,
CEQA certification). The application to the RWQCB is similar to the pre-construction
notification that is required by the U.S. Army Corps of Engineers (see discussion of Section 404,
below). It must include a description of the habitat that is being impacted, a description of how
the impact is proposed to be minimized and proposed mitigation measures with goals, schedules,
and performance standards. Mitigation must include a replacement of functions and values, and
replacement of wetland at a minimum ratio of 2:1, or twice as many acres of wetlands provided
as are removed. The RWQCB looks for mitigation that is on site and in-kind, with functions and
values as good as or better than the water-based habitat that is being removed.
Clean Water Act, Section 404: As part of its mandate under the Clean Water Act, the EPA
regulates the discharge of dredged or fill material into “Waters of the U.S.” under Section 404 of
the Act. “Waters of the U.S." include territorial seas, tidal waters, and non-tidal waters in addition
to wetlands and drainages that support wetland vegetation, exhibit ponding or scouring, show
obvious signs of channeling, or have discernible banks and high water marks. The EPA also
regulates excavation and changes in drainage. The discharge of dredged or fill material into
waters of the U.S. is prohibited under the Clean Water Act except when it is in compliance with
Section 404 of the Act. Enforcement authority for Section 404 was given to the U.S. Army
Corps of Engineers, which it accomplishes under its regulatory branch.
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The Fire Management Plan does not require direct impacts in streams, but there are wetlands in
Pearson-Arastradero Preserve in the area of treatments A.E.1, A.Rx.1, A.Rx2, A.C.3, and
A.C.11. No state and federal permits will be necessary if recommended avoidance and
protection measures are included. Creeks, ponds and wetlands are also considered a sensitive
habitat under CEQA, and can support listed species.
2.3. State
2.3.1. California Environmental Quality Act (CEQA)
CEQA (Public Resources Code Sections 21000 et. seq.) requires public agencies to review
activities which may affect the quality of the environment so that consideration is given to
prevent damage to the environment.
Under the CEQA Guidelines (Title 14 C.C.R. Sections 15000 et. seq.), Section 15307, actions
taken by regulatory agencies for the protection of natural resources such as the Palo Alto
Foothills Fire Management Plan are categorically exempt. However, if the project is located in a
sensitive environment, an ordinarily insignificant project may actually have significant effects.
Thus, under the Guidelines a project is not categorically exempt if it “may impact an
environmental resource of hazardous or critical concern where designated, precisely mapped,
and officially adopted pursuant to law by federal, state, or local agencies.” Pursuant to the
Guidelines, any project contributing to significant cumulative impacts or that has a reasonable
possibility of causing a significant effect on the environment due to unusual circumstances
cannot be exempt. The state maintains a list of sensitive, or “special-status”, biological
resources, including those listed by the state or federal government or the California Native Plant
Society as endangered, threatened, rare or of special concern due to declining populations.
Projects that directly impact these resources may not qualify for a categorical exemption. For
example, discing that could cause “take” of a burrowing owl (California Species of Concern)
would not qualify for a categorical exemption under CEQA.
The CEQA Guidelines contain a checklist of questions to gauge whether a project will result in
significant impacts. The response to these questions is included in section 6.0 of this document.
During CEQA analysis, the California Natural Diversity Database (CNDDB) is usually
consulted. The CNDDB relies on information provided by the California Department of Fish
and Game, the U.S. Fish and Wildlife Service, the California Native Plant Society, and the
Audubon Society among others. Under CEQA, the lists kept by these and any other widely
recognized organizations are considered when determining the impact of a project.
CEQA Guidelines Section 15380 defines endangered, threatened, and rare species for purposes
of CEQA and clarifies that CEQA review extends to other species that are not formally listed
under the state or federal Endangered Species Acts but that meet specified criteria. The state and
federal governments keep lists of such “special-status” species which are reflected in the
CNDDB. Many of these species are not listed under either Endangered Species Act but are
currently tracked to determine if listing is necessary. Thus they are not specifically protected by
the state and federal Endangered Species Acts. They are only protected through measures
imposed as a result of CEQA review. The California Native Plant Society has a list of plants that
are considered to be rare, threatened, or endangered in a portion or all of their range; these plants
may not have been listed by the California Department of Fish and Game or the U.S. Fish and
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Wildlife Service, but they are considered sensitive under CEQA. The California Department of
Fish and Game is a trustee agency and is solicited for its comments during the CEQA process
unless a project is exempt. The state also maintains a list of fully-protected species, as described
in section 3.3.3, below.
Foothills Park and Pearson-Arastradero Preserve provide habitat for several Special-status
species (see the discussion in section 4.0), however few of them have been confirmed present
there (Table 3-1):
Table 2-1 Potential Special-status Species of Foothills Park and Pearson-Arastradero
Preserve
Animals Plants
San Francisco dusky-footed woodrat*
Pallid bat
Red bat
American badger
Ringtail
San Francisco garter snake
Western pond turtle
California red-legged frog
California tiger salamander
Rainbow trout/steelhead*
White-tailed kite*
Northern harrier
Sharp-shinned hawk
Cooper’s hawk*
Golden eagle
Burrowing owl
Long-eared owl
Loggerhead shrike*
Yellow warbler
Saltmarsh common yellowthroat
Tri-colored blackbird
Arcuate bush mallow*
Choris’ popcorn flower
Crystal Springs lessingia
Dudley’s lousewort
Fountain thistle
Fragrant fritillary
Franciscan onion
Kings Mountain manzanita
Marin western flax
San Francisco campion
San Francisco collinsia
San Mateo thornmint
Santa Clara red ribbons
Santa Cruz Mountains manzanita
Western leatherwood*
White-flowered rein orchid
Wooly-headed lessingia
* confirmed present
2.3.2. California Endangered Species Act (CESA)
CESA (Fish and Game Code 2050 et seq.) establishes the policy of the State to conserve, protect,
restore, and enhance threatened or endangered species and their habitats. CESA mandates that
State agencies shall not approve projects that would jeopardize the continued existence of
threatened or endangered species if reasonable and prudent alternatives are available that would
avoid jeopardy.
No state-listed plant species are known to occur in Pearson-Arastradero Preserve, Foothills Park,
or the immediate vicinity.
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2.3.3. California Fish and Game Code
CDFG is authorized under the California Fish and Game Code, Sections 1600-1607 to develop
mitigation measures and enter into Streambed Alteration Agreements with applicants who
propose projects that would obstruct the flow of, or alter the bed, channel, or bank of a river or
stream in which there is a fish or wildlife resource, including intermittent and ephemeral streams.
No such activities are necessary under the Fire Management Plan.
Sections 3500-3516, 4700, 5050 and 5515 address Fully Protected species. Prior to the passage
of CESA, the classification of Fully Protected was the State’s initial effort to identify and
provide additional protection to those animals that were rare or faced possible extinction.
Subsequently, many Fully Protected species have been listed under the state and/or federal
Endangered Species Acts. The only exceptions are golden eagle, white-tailed kite, trumpeter
swan, northern elephant seal, and ringtail. Fully Protected species may not be taken or possessed
at any time and no licenses or permits may be issued for their take except for collecting these
species for necessary scientific research and relocation of the bird species for the protection of
livestock. State Fully Protected species that may occur in Foothills Park and Pearson-
Arastradero Preserve are the San Francisco garter snake, white-tailed kite, and ringtail.
Nesting birds, including raptors, are protected by the California Fish and Game Code section
3503, which reads, “It is unlawful to take, possess, or needlessly destroy the nest or eggs of any
bird, except as otherwise provided by this code or any regulation made pursuant thereto.” In
addition, under Fish and Game Code section 3503.5, “it is unlawful to take, possess, or destroy
any birds in the orders Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or
destroy the nest or eggs of any such bird except as otherwise provided by this code or any
regulation adopted pursuant thereto”. Passerines and non-passerine landbirds are further
protected under the Federal Migratory Bird Treaty Act. As such, the CDFG typically
recommends surveys for nesting birds that could potentially be directly (actual removal of
trees/vegetation) or indirectly (noise disturbance) impacted by project-related activities.
Disturbance during the breeding season could result in the incidental loss of fertile eggs or
nestlings, or otherwise lead to nest abandonment. Disturbance that causes nest abandonment
and/or loss of reproductive effort is considered “taking” by the CDFG. This code applies to
work proposed under the Fire Management Plan.
2.3.4. State Water Resources Control Board/Regional Water Quality Control Board
The State Water Resources Control Board is a five-member board that sets statewide policy
related to water quality, coordinates and supports regional water quality control boards, and
reviews petitions that contest regional board actions. There are nine regional water quality
control boards statewide; the City of Palo Alto is under the San Francisco Bay Regional Water
Quality Control Board.
Each regional board has nine board members and a staff. Each regional board sets water quality
standards, waste discharge requirements for its region, determines compliance with those
standards, and takes enforcement action. The regional board issues and enforces permits for
discharge of treated water, landfills, stormwater runoff, filling of any surface waters or wetlands,
dredging, agricultural activities and wastewater recycling. In Palo Alto, the San Francisco Bay
Regional Water Quality Control Board would be concerned with stormwater runoff and activities
that directly impact creeks, ponds or wetlands. Also see the discussion under federal Clean
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Water Act, above. None of the activities associated with the Fire Management Plan are expected
to require authorization from the Regional Water Quality Control Board.
2.4. City of Palo Alto
Tree Preservation Ordinance (Municipal Code Title 8). The City of Palo Alto tree preservation
ordinance protects coast live oak (Quercus agrifolia), valley oak (Quercus lobata), redwood
(Sequoia sempervirens), and designated heritage trees. Under the ordinance, coast live or valley
oaks that are 11.5 inches in diameter (36 inches circumference), and redwoods that are 18 inches
in diameter (57 inches circumference), measured at 54 inches above grade, are protected.
Removal of a protected tree is prohibited except when the tree is dead, hazardous, is crowding
another protected tree or constitutes a public nuisance. In some cases a protected tree can also be
removed if it affects a single-family residence or a non-residential building. A permit is required
to remove a protected tree, and replacement is normally required. The ordinance also prohibits
pruning of more than 25 percent of the crown of a protected tree within one calendar year or
unbalancing the tree.
Heritage trees are individual trees of any size or species that are specifically designated as a
heritage tree by the city council. There are no Palo Alto-designated heritage trees in the
Foothills Fire Management Plan Update area.
Palo Alto Municipal Code Chapter 18.28 Special Purpose (PF, OS and AC) Districts. The
Pearson-Arastradero Preserve and Foothills Park are subject to the municipal code governing
open space and public facility districts. The districts have the following purposes that apply to
these parks (section 18.28.010):
(a) Public Facilities District (PF)
The PF public facilities district is designed to accommodate governmental, public utility,
educational, and community service or recreational facilities.
(b) Open Space District (OS)
The purpose and intent of this district is to:
(1) protect the public health, safety, and welfare;
(2) protect and preserve open space land as a limited and valuable resource;
(3) permit the reasonable use of open space land, while at the same time preserving and
protecting its inherent open space characteristics to assure its continued availability for
the following: as agricultural land, scenic land, recreation land, conservation or natural
resource land; for the containment of urban sprawl and the structuring of urban
development; and for the retention of land in its natural or near-natural state, and to
protect life and property in the community from the hazards of fire, flood and seismic
activity; and
(4) coordinate with and carry out federal, state, regional, county, and city open space
plans.
In the “Additional OS District Regulations”, the “removal of trees shall be permitted only as
provided in Title 8” (which is tree protection, as described above). No other provisions apply to
the Fire Management Plan because it does not include development of structures. The Fire
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Management Plan helps to meet several of the purposes of the regulations, including 1, 2, and 3
listed above.
3.0 Biological Setting
3.1. Vegetation Communities
The foothills of the City of Palo Alto are located on the eastern slope of the Santa Cruz
Mountains (Figures 1, 2, and 3). The terrain transitions from low rolling foothills in Pearson-
Arastradero Preserve to steep slopes in Foothills Park. Dry conditions in the summer and fall
affect the type and location of vegetation found within the foothills. The area is drained by both
intermittent and perennial streams, including Los Trancos Creek (perennial), Arastradero Creek
(perennial), Buckeye Creek (intermittent), and an unnamed tributary to Los Trancos Creek
(intermittent) (see more discussion about creeks under Creek/Riparian Forest below).
The Santa Cruz Mountains has two life zones, the Upper Sonoran and Transition, both of which
are found within the foothills of the City of Palo Alto (Thomas, 1961). The Upper Sonoran is
composed of chaparral, grassland and foothill woodland. The Transition is composed of coastal
strand, coastal scrub, redwood forest, mixed evergreen forest, and grassland. The distribution of
these communities is determined by the availability of water.
Foothills Park and Pearson-Arastradero Preserve contain several general plant
communities/habitat types, which are described below: chaparral, coastal scrub, grassland, mixed
evergreen forest, oak woodland, serpentine soils, creek/riparian forest, lake, and irrigated
meadow. The following descriptions are based on the Flora of the Santa Cruz Mountains
(Thomas 1961), Description of Terrestrial Natural Communities of California (Holland 1986), A
Manual of California Vegetation (“MCV”) (Sawyer and Keeler-Wolf 1995), and the Jepson
Manual (Hickman, 1993). The community names are from the Flora of the Santa Cruz
Mountains (with a translation to the MCV provided), and the plant names are from the Jepson
Manual.
Pearson-Arastradero Preserve is dominated by grassland (native and non-native), but also
contains oak woodland, coastal scrub, wetland and aquatic/riparian vegetation. Foothills Park is
dominated by oak woodland and mixed evergreen forest, and also contains chaparral, coastal
scrub and aquatic/riparian vegetation.
The woodland in Pearson-Arastradero Preserve and Foothills Park is dominated by coast live
oak. As elevation increases, the oaks tend to give way to a mix of evergreens, including
madrone, bay laurel, tan oak, and buckeye. For the purposes of this analysis, these two
woodland types were combined into “woodland” because the impacts and protection measures
are not well differentiated between the two types, and it is simpler to apply the protection
measures without having to determine which woodland type is present.
Chaparral (MCV: Chamise series) Found primarily in Foothills Park, this vegetation
community occupies steep, dry south-facing slopes. It is not usually uniform in growth and is
found on rocky soils. Composed of broad-leaved sclerophyll1 shrubs usually 5-14 ft tall.
Dominant species is chamise (Adenostoma fasciculatum), but this type may also include
1 Sclerophyll means the leaves are tough and grow close together along the stem.
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manzanita (Arctostaphylos spp.), scrub oak (Quercus berberidifolia), California-lilac (Ceanothus
spp.), redberry (Rhamnus crocea ssp. crocea), coffeeberry (Rhamnus californica ssp.
californica), and holly-leafed cherry (Prunus ilicifolia ssp. ilicifolia).
Coastal Scrub (MCV: Coyote brush series) Usually less than six feet tall and found in dense
thickets on windy exposed sites with shallow, rocky soils, coastal scrub is found in both Pearson-
Arastradero Preserve and Foothills Park. Characteristic species include: coyote brush (Baccharis
pilularis), sagebrush (Artemisia californica), California-lilac (Ceanothus thyrsiflorus), California
bee plant (Scrophularia californica), blackberry (Rubus ursinus), toyon (Heteromeles
arbutifolia), poison oak (Rhus diversiloba).
Grassland (MCV: Foothill needlegrass series; California annual grassland series). Grasslands
within Foothill Park and Pearson-Arastradero Preserve are mostly non-native species due to
urban development and a long history of agriculture. However, stands of native grasses are
present in Pearson-Arastradero Preserve, and the Preserve also contains areas of serpentine
grassland (see discussion of serpentine, below). The native grasslands are dominated by
perennial bunch grasses, primarily needlegrass (Nasella pulchra, N. lepida), but also including
blue wild rye (Elymus glaucus).
California annual grasslands in the foothills in general are dominated by annual grasses and
herbaceous plants as well as containing the perennial bunchgrasses mentioned above. The non-
native species out-number native species. Characteristic species in annual grasslands include
oatgrass, annual agoseris (Agoseris heterophylla), oat (Avena fatua), golden brodiaea (Brodiaea
lutea), ripgut grass (Bromus diandrus), soft chess (Bromus hordeaceus), barley (Hordeum
murinum ssp. leporinum), foxtail barley (H. jubatum), California poppy (Eschscholzia
californica), Ithuriel’s spear (Tritileia laxa), soap plant (Chlorogalum pomeridianum), Italian
ryegrass (Lolium multiflorum), needlegrass, California fescue (Festuca californica) and six-
weeks fescue (F. dertonensis).
Mixed Evergreen Forest (MCV: various series within Mixed Live Oak Forests). This
community lies adjacent to creek/riparian forests on drier sites. It is found in the upland and
western portion of Foothills Park and southwestern portions of Pearson-Arastradero Preserve.
This community has many different subordinate communities like oak-madrone, fir-tanbark, oak-
buckeye, tanbark oak-madrone but these stands are intermittent and small in extent and area. It
is dominated by broad-leafed trees, 30 – 90 feet tall.
The mixed evergreen forest in the foothills contains a mix of tree species including coast live
oak, Pacific madrone (Arbutus menziesii), tan oak (Lithocarpus densiflorus), California buckeye
(Aesculus californica), California bay laurel (Umbellularia californica) and black oak (Quercus
kelloggii), with minor components of big leaf maple (Acer macrophyllum), coast redwood
(Sequoia sempervirens) and Douglas-fir (Pseudotsuga menziesii var. menziesii). The shrub layer
is minimal but includes saplings, western sword fern (Polystichum munitum), California hazel
(Corylus cornuta var. californica), poison oak, and broom species.
Oak Woodland (MCV: Coast live oak series). Oak woodland is a highly variable woodland
that can be dominated by blue, coast live or interior live oaks. It consists mainly of dense
woodlands with shrubby understories. Characteristic species include coast live oak (Quercus
agrifolia), valley oak (Q. lobata), blue oak (Q. douglasii), black oak (Q. kelloggii), interior live
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oak (Q. wislizenii), California buckeye, ceanothus species, California bay laurel, holly-leafed
cherry, bitter cherry (P. emarginata), toyon, and tan oak (Lithocarpus densiflorus).
Creeks/Riparian Forest (MCV: Coast live oak series; Arroyo willow series). In the foothills
area, this vegetation is found on Los Trancos Creek, Arastradero Creek, Buckeye Creek (a
tributary to Los Trancos Creek), and an unnamed tributary to Los Trancos Creek in Pearson-
Arastradero Preserve. In many places the vegetation along the creek is not markedly different
from adjacent, upslope vegetation, and is dominated by coast live oak, coyote brush, or mixed
evergreen forest. The riparian designation typically extends 50 feet from the top of the creek
bank.
Serpentine Soils. The underlying geology and the soil types in the foothills are an important
consideration with regard to special-status plant species. In this area, soils that come from
serpentine bedrock are low in nutrients and have a high calcium: magnesium ratio. As a result,
these soils support a high number of native plants that have adapted to grow in them. Non-native
grasses that can out-compete native species elsewhere do not grow well in serpentine soils
without fertilizer. Several special-status plants are now only found growing in serpentine soils.
Two areas of serpentine soils are mapped in Pearson-Arastradero Preserve, and none are mapped
in Foothills Park. Several special-status plants known to occur in the region, either historically
or currently are found on serpentine soils. The micro-habitat description for these plants is
described in Table 1 in Appendix A, and more discussion of these species is provided in section
4.2.
Lake (Bulrush-Cattail series). This habitat type occurs at Boronda Lake in Foothills Park and
John Sobey Pond and Arastradero Lake in Pearson-Arastradero Preserve. It includes wetland
vegetation such as broadleaf cattail (Typha latifolia), narrowleaf cattail (T. angustifolia) and tule
or bulrush (Scirpus spp.).
Boronda Lake is the largest of the three water bodies. It is a perennial man-made lake with a
well-developed margin of cattails and tules. It flows into Los Trancos Creek. Arastradero Lake
is next largest. It is also man-made with a dam on Arastradero Creek and is perennial. It is
surrounded by willow riparian vegetation, and has a margin of cattails and tules. John Sobey
Pond lies between Boronda and Arastradero Lakes. It is a smaller man-made impoundment on
Arastradero Creek, and is surrounded by willow riparian forest. It dries completely in low-
rainfall years.
Irrigated meadow (No MCV designation). Foothills Park contains a non-native grass, irrigated
meadow in Las Trampas Valley. The meadow extends from the Pine Gulch and Orchard Glen
picnic areas to the Oak Grove Group Picnic Area, and lies between the main park road and
Buckeye Creek.
3.2. Special-status Species
The plant and animal special-status species historically known to occur in within a five-mile
radius of Pearson-Arastradero Preserve and Foothills Park were researched through the
California Natural Diversity Database (CNDDB). A table of special-status species considered in
this analysis is included in Appendix A (Table 1). Some species that were considered are not
expected to occur in the habitat that exists in the Park or Preserve, or the database records are
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over fifty ears old. The special-status species of concern for this impacts analysis are described
below, in alphabetical order.
American badger (Taxidea taxus, California Species of Special Concern). This is an
uncommon species, but has a widespread range throughout the west. Badgers prefer to live in
dry, open grasslands, fields, and pastures. They are found from high alpine meadows to sea
level. Prey includes pocket gophers, ground squirrels, moles, woodrats, deer mice, and voles.
Badger has been found to occur within 5 miles of the town center; the last observation was in
1981 near the Stanford Linear Accelerator Center. It could occur in grassland or oak savanna
where there is friable soil. Suitable habitat occurs in Pearson-Arastradero Preserve.
Bats. The pallid bat (Antrozous pallidus, California Species of Special Concern) and red bat
(Lasiurus blossevillii, California Species of Special Concern) are listed as state species of
concern. All bat species are also protected under CDFG code.
The pallid bat prefers rocky outcrops, cliffs, and crevices with access to open habitats such as
grassland or oak savanna for foraging. It is very sensitive to disturbance of roosting sites. Such
sites are essential for metabolic economy, juvenile growth and as night roosts to consume prey.
This species was observed in Woodside in 1960, according to the CNDDB. It is also known to
occur to the north of Town in the Jasper Ridge Biological Preserve. Suitable habitat occurs in
both the Preserve and the Park.
The red bat is a migratory species and is generally found in the Bay Area in the winter. It is a
solitary roosting species that primarily uses trees as roost sites. Maternity roosts are colonial.
The roost sites are often in edge habitats, adjacent to streams, fields or urban areas, and may be
from 2 to 40 feet above ground. Red bats eat a variety of insects, mainly moths, crickets, beetles
and cicadas. It forages over open areas, and requires a source of water (Zeiner et al., 1990).
Suitable habitat for this species occurs in both the Preserve and the Park.
Some species that are otherwise not protected by the ESA or CESA and do not have a special
CDFG or Fish and Game Code designation (e.g., fully protected) may still, under CEQA, be
determined to be significantly impacted by a project. Considered nongame mammals, bats are
protected by CDFG Code 4150, which reads “all mammals occurring naturally in California
which are not game mammals, fully protected mammals, or fur-bearing mammals, are nongame
mammals. Nongame mammals or parts thereof may not be taken or possessed except as
provided in this code or in accordance with regulations adopted by the commission.”
The CEQA planning process provides the main protection for bat roosts and maternity colonies.
If a project were to destroy or disturb a roosting site for a bat maternity colony it could
significantly impact the local and/or regional population of the species. Although loss of an
individual bat would likely be considered an insignificant impact, loss of a roost site where
multiple individuals are present would be considered significant, particularly for those listed as
California species of special concern. This is because roost sites may be limited in availability
and often have very specific habitat and/or microclimate conditions. When a roost site is lost,
individuals may not be able to find an alternate roost in sufficient time for protection from the
elements before expiring. Because the type of roost varies among species, the survey
requirements also differ. A summary of habitat requirements is provided in Table 2 in Appendix
A.
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For the eleven bat species that are expected to occur in the area listed in Table 2., roost habitats
include tree cavities, caves, buildings, leaves of large trees/shrubs, rock piles, tree bark, and
mines. Most occur year round. Breeding occurs in the winter and young are generally born May
to July. In some cases the roosts are obvious by sight or smell; in other cases an acoustic survey
is necessary.
Burrowing owl (Athene cunicularia; California Species of Special Concern). Burrowing owl is
a yearlong resident of open, dry grassland and desert habitats and also occurs in grass,
herbaceous plant and open shrub stages of pinyon-juniper and ponderosa pine habitats. It eats
mostly insects, but also small mammals, reptiles, birds, and carrion. It uses ground squirrel
burrows for cover and nesting. Burrowing owl is known to occur at the Palo Alto Baylands and
in the Stanford foothills near Felt Lake. Suitable habitat occurs in Pearson-Arastradero Preserve.
California red-legged frog (Rana aurora draytonii; Federally Threatened and California
Species of Special Concern; CRLF hereafter). The California red-legged frog occurs in
grassland, riparian woodland, oak woodland, and coniferous forest but requires quiet freshwater
pools, slow-flowing streams, and freshwater marshes with heavily vegetated shores for breeding.
These frogs typically stay near the shore hidden in vegetation rather than in open water. Red-
legged frogs frequently occupy seasonal bodies of water, and in some areas these habitats may be
critical for persistence. It is speculated that CRLF may lie dormant during dry periods of the
year or during drought, utilizing animal burrows to estivate.
CRLF are thought to disperse widely during autumn, winter, and spring rains. Juveniles use the
wet periods to expand outward from their pond of origin and adults may move between aquatic
areas from summering habitat to breeding locations. Frogs disperse through many types of
upland vegetation and use a broader range of habitats outside of the breeding season. California
red-legged frogs have been observed to make long-distance movements that are straight-line,
point to point migrations rather than using corridors for moving in between habitats. Dispersal
distances are considered to be dependent on habitat availability and environmental conditions
(USFWS 2008).
Other important microhabitat features include overhanging vegetation, such as willow boughs
that contact the water, overhanging banks formed by tree-root masses and retreat sites at water
levels that are close to relatively deep, still water. Adult CRLF are strongly associated with these
microhabitats during surface activity (Jennings and Hayes, 1994).
CRLF are known to occur in Matadero Creek, Deer Creek, San Francisquito Creek, at Lawler
Ranch, in Corte Madera Creek (at the end of Bear Gulch Road), and southeast of La Honda in
privately owned ponds. They could also occur in Los Trancos Creek and Sausal Creek in Portola
Valley.
A reconnaissance survey of John Sobey Pond and Arastradero Lake for CRLF was done in 1998
by experts Rich Seymour and Mike Westphal. They found that both ponds are inhabited by
bullfrogs (a predator on red-legged frog), and deduced that CRLF is absent or occurs in very low
numbers. John Sobey pond was found to more closely resemble pool and sag pond habitat found
elsewhere in the coast range, whereas Arastradero lake was found to be atypical California
habitat and a source for non-native predators and competitors of native amphibians. Their report
(Seymour and Westphal, 1998), recommends modifications to Arastradero Lake to improve
habitat quality, allowing John Sobey Pond to dry regularly to control the bullfrog population,
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prohibiting the use of mosquitofish, and undertaking an eradication program to reduce the
bullfrog population.
California tiger salamander (Ambystoma californiense, Federal Threatened, California Species
of Special Concern; CTS hereafter). CTS was listed by the USFWS as federally Threatened in
September 2004. CTS range from the Sierra Nevada crest (just west of it) to the outer coast
range and from Sonoma and Yolo counties on the north to Santa Barbara County in the south.
CTS require a mosaic of habitats consisting of seasonally filled pools located in or near
grasslands or oak woodlands. Semi-permanent ponds, reservoirs, and portions of slow-moving,
seasonal creeks may also be used. For most of the year, CTS live in the burrows of ground
squirrels, gophers, and other rodents in open wooded or grassy areas. However, they may also
use man-made structures such as underground utility boxes and drainage pipes. They do not
emerge to breed every year. The only known population of CTS on the peninsula occurs on
Stanford lands near Lagunita. It was also reported to occur on Albion Avenue in Woodside in
1962. Suitable habitat for CTS is present in Arastradero Preserve, but it has never been observed
there.
Long-eared Owl (Asio otus; California Species of Special Concern). The long-eared owl
frequents dense, riparian and live oak thickets near meadow edges, as well as nearby woodland
and forest habitats. It eats mostly voles and other rodents, occasionally birds, and other
vertebrates. It may be found in oak woodland, oak savanna, mixed evergreen forest, redwood
forest, and creek-riparian habitats. It 1987 it was observed nesting in the Monte Bello Open
Space Preserve, to the southwest of the Park and Preserve, which was the first confirmed
breeding location in Santa Clara County. Suitable breeding habitat occurs in both Pearson-
Arastradero Preserve and Foothills Park.
Saltmarsh common yellowthroat (Geothlypis trichas sinuosa; California Species of Special
Concern). The saltmarsh common yellowthroat mostly breeds and winters in wet meadow, fresh
emergent wetland, and saline emergent wetland habitats in areas around the south end of San
Francisco bay. It eats insects, especially caterpillars and other larvae; also spiders and seeds.
Breeding pairs were observed in the marsh at the south end of Searsville Lake in 1976 and 1985.
The habitat at the lake includes dense freshwater marsh vegetation with willows and cattails as
the dominant plant species. Breeding habitat is present at Arastradero Lake and Boronda Lake.
Loggerhead shrike (Lanius ludovicianus; California Species of Special Concern). The
loggerhead shrike is a medium-sized songbird that breeds and forages in open areas with short
vegetation, such as pastures and open woodlands. It eats insects, amphibians, small reptiles,
small mammals, and birds. It uses its strong beak to capture its prey, and then impales the prey
on a thorn or barbed wire in order to hold it while eating it. It is known to occur at Stanford, and
is expected to occur in Pearson-Arastradero Preserve.
Cooper’s hawk (Accipiter coopersii; California Department of Fish and Game Watch List). The
Cooper’s hawk is a medium-sized hawk that lives in forest habitats. It prefers dense canopied
evergreen and deciduous forests or riparian zones. Its main prey item is birds. It is known to
occur at Stanford, and is expected to occur in both Pearson-Arastradero Preserve and Foothills
Park.
Sharp-shinned hawk (Accipiter striatus; California Department of Fish and Game Watch List).
The sharp-shinned hawk prefers coniferous, mixed evergreen forests and riparian forest. It is a
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winter resident of the Bay Area, and is not expected to breed here. It preys on birds. It is known
to occur at Stanford, and suitable habitat is present in Pearson-Arastradero Preserve and Foothills
Park.
Raptors (birds of prey). Birds of prey are also protected by California Fish and Game Code, as
noted earlier. This includes any raptor, regardless of whether it is a special-status species.
Raptors known to breed in the area include loggerhead shrike, white-tailed kite, northern harrier,
sharp-shinned hawk, Cooper’s hawk, red-shouldered hawk, red-tailed hawk, golden eagle,
American kestrel, prairie falcon, barn owl, western screech-owl, great horned owl, northern
pygmy-owl, and northern saw-whet owl (Sequoia Audubon Society, April 2006). The Park and
Preserve contain suitable breeding habitat for raptors in mixed evergreen forest, oak woodland,
grassland, aquatic and creek/riparian forest vegetation types.
San Francisco dusky-footed woodrat (Neotoma fuscipes annectens; California Species of
Special Concern). The San Francisco dusky-footed woodrat (SFDW) is one of eleven subspecies
of the dusky-footed woodrat that live throughout California and the arid west. The range of the
San Francisco dusky-footed woodrat includes the coastal belt of San Francisco as far north as the
Golden Gate, as far east as Walnut Creek in Contra Costa County and Niles Canyon in Alameda
County, and south at least until the UC Santa Cruz campus (Hooper 1944). Although the dusky-
footed woodrat is generally considered common throughout its range, their complex social
structure makes them sensitive to disturbance (Santa Cruz Mountains Bioregional Council,
2004).
The SFDW, a nocturnal mammal, occurs in a variety of brushy and wooded areas that provide
cover from aerial and ground predators. Suitable SFDW habitat within the Santa Cruz
Mountains includes forests that contain Douglas-fir, manzanita, tan oak, coast redwood, and
willow species (Bankie, 2005). They are typically not found within open habitats such as
grassland, but will traverse through such habitat for mating or range expansion even at the
expense of temporary vulnerability to predators.
The SFDW eats primarily woody plants, including leaves, flowers, nuts and berries. Specific
food sources used throughout the Santa Cruz Mountains include coast live oak, coffeeberry,
blackberry, gooseberry, poison oak, and honeysuckle. It is an opportunistic feeder, and has been
observed to use non-native species as a primary food source, although these species are in the
same genus as native plants known to be used by SFDW (TRA staff observation).
The SFDW builds stick structures (houses) for nesting that average five feet long and four feet in
height. SFDWs are typically found living in colonies of 3 to 25 houses. These elaborate
dwellings help protect the SFDW from seasonal temperature extremes and predators. Various
chambers can be found within the houses, each serving a different purpose for its resident SFDW
including food storage, nesting, and latrine. Other wildlife such as amphibians, reptiles and
invertebrates also live in active SFDW houses without harm to or from SFDW. It is common for
one SFDW to use several houses. However, some female SFDWs will occupy the same house
for their entire lifespan, at which time one of her female offspring take over the house.
Consequently, some SFDW houses are actively used for as long as 30 years (SCMBC, 2004).
Male and female woodrats do not share nests; however, a female will share the nest with her
litter for several months. A male woodrat territory typically overlaps 1 to 5 female woodrat
territories but no other male territories. However, female territories will overlap with each other.
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Territory size varies greatly but male territories are typically larger than female territories. Male
territories range from 0.3 to 0.6 acres and female territories range from 0.1 to 0.5 acre.
Both Pearson-Arastradero Preserve and Foothills Park contain SFDW in woodland,
creek/riparian forest, coastal scrub and chaparral habitats.
Ringtail (Bassariscus astutus; California Fully Protected). Ringtails occur across the arid west
usually at elevations from sea level to 1400 meters. They are solitary, nocturnal and secretive,
and are known to occur in rocky areas in chaparral, oak woodland, riparian woodland, and
conifer forests, with a home range up to 336 acres. Ringtail is similar to a raccoon in
appearance, but smaller, and has a fox-like face and cat-like body. Its tail is generally longer
than its body. They are excellent climbers. Ringtails eat small animals (rodents, birds, reptiles,
and amphibians), carrion, and nuts and berries. Ringtails establish permanent dens in rock
outcrops or tree hollows. Litter size ranges from two to four, and there is one litter per year. The
CNDDB has no reported sightings of ringtail in the local area, but both the Park and Preserve
contain suitable habitat for this species and are within its known range.
San Francisco garter snake (Thamnophis sirtalis tetrataenia; State and Federally Endangered
and California Fully Protected). Historically, the San Francisco garter snake (SFGS) occurred in
scattered wetland areas on the San Francisco Peninsula from approximately the San Francisco
County line south along the eastern and western bases of the Santa Cruz Mountains, at least to
the Upper Crystal Springs Reservoir, and along the coast south to Año Nuevo Point and Waddell
Creek in Santa Cruz County (U.S. Fish and Wildlife Service 2005). The species currently
appears to be limited to small areas within this historic range; primarily along the San Mateo
County Coast and near the San Francisco International Airport.
SFGS is a highly aquatic species found in or near densely vegetated freshwater ponds with
adjacent open hillsides where they can bask, feed, and find cover in rodent burrows. Temporary
ponds and other seasonal freshwater bodies are also used. Emergent and bankside vegetation
such as cattails (Typha spp.), bulrushes (Scirpus spp.) and rushes (Juncus spp. and Eleocharis
spp.) are preferred and used for cover. The area between stream and pond habitats and
grasslands or bank sides is used for basking, while nearby dense vegetation or water often
provides escape cover. A critical component for San Francisco garter snake is the presence of
suitable prey, including Pacific tree frog (Pseudacris regilla) and ranid frogs (California red-
legged frog and/or bullfrog). The snakes breed during the spring and females deposit their eggs
near the water during the summer. The males are thought to disperse to drier areas at this time.
Throughout the fall, the adults may occupy burrows in adjacent grasslands while juveniles
remain near the water. Although very little information is available regarding dispersal and
movements through upland habitats, a percentage of young and sub-adults likely disperse and
colonize new ponds.
Urbanization destroyed the majority of prime habitat for the snake, and continues to fragment
remaining habitat and eliminate habitat linkage corridors. Illegal collection of the SFGS, CRLF
population decline, and the introduction of the American bullfrog (Rana catesbeiana) have also
led to its decline. Suitable habitat for this species is very limited in the area. An intergrade form
occurs in Woodside just north of Searsville Lake. It is unknown if the intergrade is more closely
related genetically to the common garter snake or to the SFGS. Habitat for SFGS is present at
Boronda Lake in Foothills Park and along Arastradero Creek in Pearson-Arastradero Preserve,
but the likelihood of occurrence is low.
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The Central California Coast steelhead (Oncorhynchus mykiss, Federal Threatened, California
Species of Special Concern). Steelhead is an anadromous fish that is federally listed as
Threatened. Steelhead is native to coastal streams from Baja California to Alaska and parts of
Asia. Adult steelhead migrate from the ocean into streams in the late fall, winter, or early spring
seeking out deep pools within fast moving streams to rest prior to spawning. Steelhead spawn in
shallow water gravel beds and the young typically spend the first one to two years of their lives
as residents of their natal stream.
San Francisquito Creek is thought to support one of the most robust winter steelhead runs of any
creek system flowing into San Francisco Bay, but information is not available to enumerate the
size of the adult run or the number of juvenile fish rearing in the system. Within San
Francisquito Creek, Los Trancos Creek, and Bear Creek, steelhead adult spawn, eggs incubate,
juvenile steelhead rear year-round, and steelhead smolts outmigrate during the spring months.
Young steelhead generally rear in the creeks for one to two summers. The most important
spawning and rearing habitat for steelhead in the San Francisquito Creek system is in Los
Trancos Creek, San Francisquito Creek (from Searsville Reservoir to Junipero Serra Boulevard),
and Bear Creek; however, steelhead will rear in any part of the system that has water year-round
(Alan Launer, Stanford University, pers. comm.).
Limiting factors for steelhead within the San Francisquito Creek Watershed include migration
and movement barriers, sedimentation, low summer flows, and lack of instream shelter.
Searsville Dam is a major barrier to upstream migration for steelhead, and cuts off approximately
one-third of the upper watershed to steelhead access. Water diversion facilities are also partial
barriers for steelhead migration and movement; however, most of these have been modified or
are in the process of being modified through agreements with CDFG and NOAA Fisheries.
San Francisquito Creek has been designated as “impaired for sediment” by the San Francisco
Bay Regional Water Quality Control Board (SFBRWQCB, 2006). A 2006 study of watersheds
in Santa Clara County found that in 25% of the watersheds the biggest limiting factor for
steelhead was the lack of rearing habitat for juvenile steelhead (Jones and Stokes, 2006). Los
Trancos Creek was among those creeks where lack of rearing habitat was found to be a limiting
factor. This is the result of pool filling by fine sediment, which is likely at least partially
influenced by bank instability in the upper watershed. In addition, the natural confined channel
structure of Los Trancos Creek, and the lack of instream structure such as woody debris, likely
result in steelhead young being flushed downstream during high flow events.
Steelhead may be found in Los Trancos Creek in Foothills Park and within city limits along the
Los Trancos Road evacuation route.
Western pond turtle (Actinemys marmorata; California Species of Concern). Western pond
turtle ranges in size from 3.5 to 7 inches and is the only freshwater turtle native to the San
Francisco Bay Area. It occurs in ponds, small lakes, marshes, streams and irrigation ditches with
abundant vegetation. It is also found in marshes, streams, rivers, reservoirs and occasionally
brackish water. The Western pond turtle feeds on aquatic plants (such as pond lilies), beetles,
aquatic invertebrates, fishes, frogs and carrion. It uses basking sites such as partially submerged
logs, rocks, mats of floating vegetation or open mud banks, as well as underwater retreats to hide
from predators and humans. Females deposit their eggs in nests in banks or in the case of
foothill streams, in upland areas away from the stream. Nests have been observed in many soil
types, from sandy to very hard, and have been found up to 400 meters (1300 feet) from the
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water. Certain fish species, bullfrogs, garter snakes, wading birds and some mammals prey on
hatchlings and juveniles. Western pond turtle is known to occur in low numbers in San
Francisquito Creek and in higher numbers in ponds on Midpeninsula Regional Open Space
District lands. There are no sightings of Western pond turtle in the Preserve or Park in the
CNDDB, but suitable habitat exists in the creeks and ponds.
Special-status serpentine plants. As noted in the discussion of soils, above, serpentine has
chemical properties that favor native plants. Because of this, non-native annuals are less likely
to out-compete the native plants, and this has resulted in several plants becoming more or less
confined to areas of serpentine. The following list describes special-status serpentine plants
known to occur within 5 miles of the Park and Preserve. Most of these have a very limited
distribution, and are not likely to occur in the Park or Preserve. Serpentine soils and habitat are
present in Pearson-Arastradero Preserve and provide potential habitat for some of these species:
• Fountain thistle (Cirsium fontinale var. fontinale, Federal Endangered, State Endangered,
CNPS 1B), found at the southern end of Crystal Springs Reservoir and in Edgewood
Natural Preserve in moist areas in serpentine soil. The likelihood of occurrence in the
Preserve is very low, due to habitat limitations. None of the mapped areas of serpentine
contain seeps.
• Crystal Springs lessingia (Lessingia arachnoidea, CNPS 1B), occurs on grassy slopes in
serpentine soil in coastal sage scrub, valley and foothill grassland, and cismontane
woodland habitats. The closest known occurrence is at Edgewood Natural Preserve.
This plant could occur in serpentine grassland in Pearson-Arastradero Preserve.
• Franciscan onion (Allium peninsulare var. franciscanum, CNPS 1B), was found and
mapped on Jasper Ridge in 1968. Its microhabitat is clay soils, often on serpentine, on
dry hillsides in woodland and grassland. The only other records in the CNDDB are in
1985 and 1902 on Matadero Creek and in Woodside. The likelihood of occurrence in
Pearson-Arastradero Preserve is low, but cannot be entirely ruled out.
• Marin western flax (Hesperolinon congestum, Federal Threatened, State Threatened,
CNPS 1B), is known to occur at Edgewood Natural Preserve in serpentine grassland with
needlegrass, squirreltail, soap plant, blue dicks and buckwheat. It was also found in
Woodside Glens (between I-280 and Canada Road) in serpentine grassland and at Stulsaft
Park in Redwood City in serpentine grassland, growing with mariposa lily, clarkia,
buckwheat, California poppy, tarplant and prickly lettuce. This plant is very rare and the
likelihood of its occurrence in Pearson-Arastradero Preserve is extremely low, but
suitable habitat is be present.
• San Mateo thornmint (Acanthomintha duttonii, Federal Endangered, State Endangered,
CNPS 1B), occurs on serpentinite vertisol clays in relatively open areas. Formerly
known to occur near the Menlo Country Club and Emerald Lake in Redwood City, this
plant is now only known to occur in the Edgewood Natural Preserve area. The likelihood
of this plant occurring in Pearson-Arastradero Preserve is extremely low due to its
restricted range and habitat requirements.
• White-rayed pentachaeta (Pentachaeta bellidiflora, Federal Endangered, State
Endangered, CNPS 1B), is only known from one location on the peninsula, in the triangle
west of Edgewood Natural Preserve on lands owned by the San Francisco Water
Department. It grows in open serpentine grassland. The likelihood of this plant
occurring in Pearson-Arastradero Preserve is extremely low due to its restricted range and
its habitat requirements.
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• Fragrant fritillary (Fritillaria lileacea, CNPS 1B), grows at Edgewood Natural Preserve in
serpentine grassland in association with needlegrass, soap plant, clarkia, morning glory,
delphinium, shooting star, vetch, California poppy, peppergrass, rye grass and yarrow.
The CNDDB summarizes the habitat for this species as valley and foothill grassland,
coastal prairie, and grassland patches in coastal scrub, often on serpentine but various
soils reported, usually clay. It is also known from near Farm Hill Boulevard. The
CNDDB attributes a herbarium specimen from 1894 labeled as “hills about Stanford
University” to Jasper Ridge, but notes that “other hills in the area may also support
suitable habitat”. The likelihood of this plant occurring in Pearson-Arastradero Preserve
is low due to its rarity, but cannot be ruled out.
• White-flowered rein orchid (Piperia candida, CNPS 1B), is reported in the CNDDB as
occurring in the Los Trancos Open Space Preserve (about 2.6 miles southeast of town
limits) on serpentine soils in mixed evergreen forest and coniferous forest. The
likelihood of this plant occurring in Pearson-Arastradero Preserve is nil, since all of the
mapped serpentine is in grassland habitat.
Other Special-status Plants. There are also special-status plants in the area that are not
confined to serpentine soils. These include the following:
• Arcuate bush mallow (Malacothamnus arcuatus, CNPS 1B), is a chaparral species that
has historically been found in Jasper Ridge, along Los Trancos Creek, near La Honda, at
Edgewood Natural Preserve, and in Arastradero Preserve. It grows in gravelly alluvium
in chaparral in association with grasses and coyote brush. This species is known to be
present in Pearson-Arastradero Preserve and there is a program underway to increase the
population size through propagation. It has been planted in several locations in the
Preserve and occurs near treatments A.C. 3, A.D. 2, A.C. 10, and ARx2.
• Choris’ popcorn flower (Plagiobothrys chorisianus var. chorisianus, CNPS 1B), grows in
grassland patches in chaparral and coastal scrub; its nearest observation to date is at
Crystal Springs Reservoir, to the north. There it grows in the moist soil of a meadow
surrounded by oaks and madrones. The likelihood this species occurs in the Park or
Preserve is low due to its specific habitat requirements, but its presence cannot be ruled
out.
• San Francisco campion (Silene verecunda ssp. verecunda, CNPS 1B), is reported to
historically occur at Edgewood Natural Preserve in serpentine grassland. It is also found
on mudstone or shale and in sandy soils in coastal scrub, grassland, and chaparral. The
likelihood this species occurs in the Park or Preserve is low due to its specific habitat
requirements, but its presence cannot be ruled out.
• Santa Clara red ribbons (Clarkia concinna ssp. automixa, CNPS List 4), is an annual
plant that grows in woodland and chaparral. It has been observed near Stevens Creek
reservoir in mixed evergreen forest similar to that in Foothills Park, along Page Mill
Road, along Skyline Boulevard, and along Los Trancos Road. This species could be
present in Foothills Park or along the evacuation routes.
• Western leatherwood (Dirca occidentalis, CNPS 1B), is a shrub that grows on cool, moist
slopes in woodland and creek/riparian habitat. It is known to occur along Los Trancos
Road, at Jasper Ridge, in Foothills Park, at Edgewood Natural Preserve, and in La Honda
Creek Preserve. It grows in mixed evergreen forest dominated by madrone, black oak,
coast live oak, poison oak, and bay laurel. It grows in association with coffeeberry,
manzanita, bay laurel, buckeye, elderberry, tan oak, bitter cherry, ribes and toyon. This
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species is known to occur in Foothills Park and along Los Trancos Creek, and suitable
habitat is present in Pearson- Arastradero Preserve.
• San Francisco collinsia (Collinsia multicolor, CNPS 1B), is known to occur in Edgewood
Natural Preserve, where it grows in mixed evergreen woodland in association with
western leatherwood. Suitable habitat for this plant occurs in Foothills Park and Pearson-
Arastradero Preserve as well as along the Page Mill Road, Skyline and Los Trancos Road
evacuation routes, but its likelihood of occurrence is considered low.
• Kings Mountain Manzanita (Arctostaphylos regismontana, CNPS 1B), is known to grow
in manzanita chaparral and Douglas-fir forest. It has been found along Kings Mountain
Road, in the Teague Hill Open Space Preserve northwest of Tripp Gulch in Woodside,
and near Sierra Morena in the El Corte Madera Open Space Preserve. Suitable habitat for
this species occurs in Foothills Park and along Page Mill Road and Skyline Boulevard,
but its likelihood of occurrence is low.
• Santa Cruz Mountains Manzanita (Arctostaphylos andersonii, CNPS 1B), grows in
boradleaved upland forest, chaparral and north coast coniferous forest. It is known from
Skyline Boulevard at the junction of Kings Mountain Road and Skyline, and to the north
on Skyline. Suitable habitat is present in Foothills Park and along the evacuation routes
on Page Mill Road and Skyline Boulevard.
Plant communities of concern. In addition to specific species, the CNDDB identifies plant
communities that are of concern due to declining distribution. Those that pertain to the Foothills
Fire Management Plan are serpentine bunchgrass, arroyo willow riparian and wetland.
Serpentine bunchgrass is identified in the CNDDB as occurring at Edgewood Natural Preserve
and Jasper Ridge, and it may also occur in Pearson-Arastradero Preserve. Arroyo willow
riparian occurs along Los Trancos Creek and Arastradero Creek. Wetland occurs in Pearson-
Arastradero Preserve and at Boronda Lake in Foothills Park.
In addition to these special-status species and plant communities, the Friends of Foothills Park
has identified, through observation of trail maintenance activities, a list of native plants which
are slow to regenerate along a trail once they are damaged or removed or which are unusual
sights within the park. These are primarily perennial, low-growing plant species. They are listed
in Table 3 in Appendix A.
3.3. Erosive Soils
The City of Palo Alto Foothills Fire Management Plan Update states that soils with a slope in
excess of 15 to 30 percent represent significant hazards from either fire or treatment (2008).
According to the soil survey for Santa Clara County (NRCS 1968), there are three soil types
found within the City of Palo Alto Foothills that are a high erosion hazard (see table below).
They are Maymen Rocky Fine Sandy Loam Eroded, Maymen Fine Sandy Loam Eroded, and Los
Gatos-Maymen. These soils occur along the evacuation routes and in both the Park and the
Preserve.
Table 3-1 Soil Types in the Palo Alto Foothills Area
Soil Series Soil Name Location Erosion Hazard
Los Gatos Los Gatos-Maymen Soils
(LkG3) (50-75% slope)
Foothills Park & Pearson-
Arastradero Preserve
High
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Soil Series Soil Name Location Erosion Hazard
Los Gatos Clay Loam (LgE)
(15-30% slope)
Foothills Park & Pearson-
Arastradero Preserve Moderate
Los Gatos Clay Loam,
Eroded (LgE2)
(15-30% slope)
Foothills Park & Pearson-
Arastradero Preserve Moderate
Los Osos Los Osos Clay Loam (LoE)
(15-30% slope)
Pearson-Arastradero
Preserve Moderate
Azule Azule Silty Clay Loam
(AvD2) (15-30% slope)
Pearson-Arastradero
Preserve Slight to Moderate
Cropley Cropley Clay (CrC)
(2-9% slope) Foothills Park Slight
Maymen Rocky Fine Sandy
Loam, Eroded (MfG2)
(50 – 75% slope)
P.A. 1 treatment High
Maymen Maymen Fine Sandy Loam,
Eroded (MeF2)
(15 -50% slope)
P.A. 1 treatment High (on sections with > 30%
slope)
Madonna Loam (MbE2) (5
– 30 % slope) P.A. 1 treatment Moderate
Madonna Madonna Loam (MbE) (15
– 30% slope) P.A. 1 treatment moderate
3.4. Invasive Plant Species
Invasive species are moved from one region of the world to another, usually by human activity.
They have a competitive advantage due to a lack of predators and crowd out native vegetation
and wildlife. In California roughly 3% of all plant species are invasive (Cal-IPC 2008). Though
they are a small percentage of the overall number of plant species, these species occupy a large
portion of the landscape. Public agencies are wary of invasive species because they can increase
fire loads and help to create more frequent fires.
In the City of Palo Alto foothills, management of Italian thistle (Caardus pycnocephalus I.),
yellow star thistle (Centaurea solstittialis), and French broom (Genista monospessulana) is
conducted at Foothills Park and Pearson-Arastradero Preserve. Yellow star thistle is managed in
both parks while Italian thistle is managed only in Pearson-Arastradero and French broom is
managed only in Foothills Park.
The California Invasive Plant Council (Cal-IPC) maintains an invasive plan inventory to track
the status of invasive plants within California. As part of this inventory it ranks the threats
individual plant species pose to California’s native ecology. According to Cal-IPC, Italian thistle
has a moderate ranking while yellow star thistle and French broom have a high ranking. These
rankings demonstrate the level of invasiveness for each species. However, in terms of the City
of Palo Alto Foothills Fire Management Plan Update and the effect of these species on fire,
Italian thistle and French broom cause a greater ecological impact. Both of these species can
cause an increase in fire frequency and movement of fire into the overstory in scrub, woodland
and chaparral habitats (Cal-IPC 2006).
Cal-IPC has recommended mechanical and hand-treatment for Italian thistle, French broom and
yellow star thistle. The recommended method for Italian thistle is to hand pull so that the root is
severed at least four inches (10 cm) below the ground level and well before the seed is set (Cal-
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IPC 2008b). In Pearson-Arastradero Preserve, from 2007 – 2008, 10 – 12 acres south-west of
the parking lot along Portola Pastures and Meadowlark Trails were grazed by goats to control
Italian thistle (Curt Dunn pers. comm.). Discing, mowing and prescribed burning can all be
effective at controlling yellow star thistle. However, for each of these methods it depends on the
timing of the treatment. For each method it is important to conduct the method at the beginning
of seed production when roughly two to five percent of the seed heads have matured (Cal-IPC
2008c). In Foothills Park and Pearson-Arastradero Preserve, yellow star thistle is by and large
the most invasive.
Yellow star thistle has been mowed in two locations in Foothill Park:
• five to seven acres in the Wildhorse Valley
• three acres around a flat area south of Fire-Station 8
• and in four locations in Pearson-Arastradero Preserve:
• four acres inside Gate-A near the concrete bridge
• six and a half acres near Gate-B along the Ohlone trail
• seven acres around Gate-C along Bowl Loop Trail
• 30 foot clearance around the Gateway buildings.
Cal-IPC recommends that removal of French broom be conducted by hand, a combination of
cutting and pile burning, and through prescribed burning (Cal-IPC 2008a). However, the cutting
must be done after the plant has gone to seed in July or August and five to eight centimeters
above the soil surface. The Friends of the Foothills does hand pulling of French broom at small
invasion locations throughout Foothills Park.
4.0 Impacts
This section describes the impacts of proposed treatments on vegetation communities, special-
status species, exotic invasive species, and erosion, which can adversely impact habitats.
Vegetation Communities. The Foothills Fire Management Plan updates existing fire
management practices in Pearson-Arastradero Preserve, Foothills Park, and along the evacuation
routes on Page Mill Road, Arastradero Road, Los Trancos Road, and Skyline Boulevard. It will
reduce the impacts of mowing on Trappers Trail in Foothills Park by reducing the area that is
mowed annually, and allowing some of the habitat there to recover. It will replace discing in
Pearson-Arastradero Preserve (except near Liddicoat Circle) and in Foothills Park with mowing
and/or grazing, which will restore grassland habitat.
Overall, however, the Fire Management Plan will increase the area that is treated by about 135
acres. The impacts will mainly occur in grassland, including large areas in Pearson-Arastradero
Preserve that will be grazed or subject to prescribed burn. It is estimated that, overall, about 65
more acres of grassland will be affected than under current activities. The new area of impacts to
woodland and chaparral is mainly along the evacuation routes, where vegetation management
will be expanded from the existing 10- foot zone to a 30-foot zone. Throughout the area of the
fire plan, about 47 new acres of woodland and 13 new acres of chaparral will be affected. About
one acre of riparian vegetation may be affected, primarily along Arastradero Creek but also
along Los Trancos Creek, and about 9 new acres of coastal scrub will be affected. These
estimates have been adjusted to take into account areas that will no longer be annually impacted
by current activities.
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The habitats that will be affected by the various treatments are listed in Table 3 in Appendix A.
The table also includes the measures that will be necessary to protect biological resources at each
treatment site. The measures are listed at the end of the table and in section 6.0, below.
In general, the fire management plan will result in fewer biological impacts than the current
practices. Although the total area that is treated will increase, the methods to be used will foster
restoration of native habitats. While grading, discing and brush mowing have been used in the
past, the updated plan does not require grading or discing and reduces the amount of brush
mowing. It uses hand labor and careful instructions in the amount of trimming that will occur.
The vegetation management in the plan is intended to mimic the effects of more frequent, less
intense fires which historically occurred in the area and which have been suppressed for many
years. The more frequent, less intense fires typically cleared the undergrowth in the forest,
reduced “ladder” fuels that could carry fire into the tree canopy where more intense damage
could start, and opened areas to new plant growth. Grassland fires reduced thatch and fostered
native plant diversity.
Several studies related to range management indicate that methods used to mimic historic fire
patterns enhance native plant diversity. In DiTomaso et.al. (1999), prescribed burning of
grassland in Sugarloaf Ridge State Park in Sonoma County resulted in a dramatic increase in
total plant diversity and species richness, and significantly reduced the seedbank of the invasive
non-native weed, yellow star-thistle. In a study in seven nature preserves in the Czech Republic,
Dostalek and Frantik (2008) found that low-intensity goat grazing in dry grassland can help to
keep the dry grassland in good condition and conserve its plant diversity. Dodson et.al. (2007)
studied restoration treatments in ponderosa pine/Douglas-fir forests that included thinning,
burning and a combination of thinning and burning. It was found that active restoration
treatments in these forests may foster plant diversity by minimally impacting common species
while significantly benefiting disturbance-dependent native species.
Grazing is one of the tools proposed in the fire management plan, and it could be used in all
vegetation types except riparian forest. Overgrazing can adversely impact vegetation
communities. The fire management plan includes best management practices that require a
grazing management plan be prepared to insure proper stocking levels. A measure is also
recommended that protects wetlands in Pearson-Arastradero Preserve from grazing (see BMP-13
and BIO-8 in section 6.0, below).
Special-status Species. Implementation of the fire management plan could impact several
special-status species. Measures to avoid those impacts, which are also required to comply with
California Fish and Game Code and the Migratory Bird Treaty Act, are described in Section 6.0.
The special-status species that are known to occur in the Foothills Fire Management Plan area
are Steelhead (Los Trancos Creek), San Francisco dusky-footed woodrat (throughout), white-
tailed kite (breeding in Pearson-Arastradero), arcuate bush mallow (Pearson-Arastradero), and
western leatherwood (Foothills Park and Los Trancos Creek). Suitable habitat for several others
exists, as described in 4.0 above, but their presence has not been verified. The special-status
species in each vegetation type are listed in Table 4 in Appendix A, and impacts are described
below.
American badger and burrowing owl could occur in grasslands in Pearson-Arastradero Preserve.
The Fire Management Plan Update removes discing in the grassland and will improve habitat for
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these species. The area next to Liddicoat Circle that may continue to be disced has been disced
annually for several years and does not provide burrow habitat for badger or burrowing owl.
Bats may roost in tree crevices and tree bark throughout the woodlands in the fire management
plan area. A significant impact would occur if a maternal roost is removed or significantly
disturbed by cutting down a tree that contains such a roost. Tree removal may occur under the
fire management plan, including thinning stands along the evacuation routes and removing
individual eucalyptus trees. A pre-removal survey for bat roosting activity is recommended (see
measure BIO-4).
California red-legged frog, California tiger salamander, San Francisco garter snake, Western
pond turtle, and steelhead are aquatic-dependent species. Of these, only steelhead is confirmed
present in Los Trancos. The frog, salamander, and turtle also have an upland habitat component,
as they use burrows near creeks and ponds for part of the year. The Foothills Fire Management
Plan Update does not require work in streams or ponds. It does require trimming of riparian
vegetation along Arastradero Creek and a small section of Los Trancos Creek. The prescription
for riparian vegetation is to avoid it, or if necessary to trim it, to do so every 10 to 15 years. The
fire plan reduces discing, and does not require work that would impact burrows. The plan would
not significantly impact these species. In the event that discing is implemented in the future,
measure BIO-5 is included for protection of these species.
Long-eared owl, saltmarsh common yellowthroat, loggerhead shrike, Cooper’s hawk,
sharp-shinned hawk, other raptors (birds of prey), and nesting birds could be adversely affected
by vegetation trimming under the Foothills Fire Management Plan Update that occurs during the
breeding season. Avoidance of active bird nests is recommended (see measure BIO-1) by
avoiding work during the breeding season or conducting a pre-removal survey for active bird
nests and avoiding those during the breeding season. This applies to all designations in all
vegetation types. Vegetation management activities that foster plant diversity will benefit
wildlife species, including birds, and it is expected that vegetation management under this fire
plan will foster plant diversity.
San Francisco dusky-footed woodrat occurs in woodland, creek/riparian forest, coastal scrub, and
chaparral habitat throughout the Foothills Fire Plan Update area. Because the SFDW houses
look like a pile of woody debris, these are at risk of being removed during vegetation
management activities. A pre-work survey and worker education program is recommended
under measure BIO-3, and it would apply to all of the treatment designations except those in
grassland. The houses should be avoided and left with a five-foot buffer.
Ringtail has a low likelihood of occurrence in the fire management plan area. Vegetation
management will not remove dens or nest sites and is not expected to impact this species.
Special-status serpentine plants can occur where there are serpentine soils. Serpentine soils are
mapped in Pearson-Arastradero Preserve in grassland habitat. These areas are proposed to be
either left untreated or to be mowed/grazed. Pre-work surveys of these areas are recommended
to avoid impacts to rare plants (see measure BIO-2).
Other Special-status Plants occur in woodland, chaparral, coastal scrub and riparian forest
habitats in the fire management plan area. Western leatherwood is known to occur in Foothills
Park and along Los Trancos Creek, where it has been damaged in the past by roadside trimming.
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It is recommended that pre-work surveys be conducted during the bloom period of rare plants,
and that any found be marked, mapped and avoided (see measure BIO-2.
Plant communities of concern in the fire management plan area include arroyo willow riparian
and wetland. These communities could be affected by fire management plan activities in
Pearson-Arastradero Preserve and along Los Trancos Creek where there is arroyo willow.
Patches of wetland vegetation occur in the grassland areas of Pearson-Arastradero Preserve, and
arroyo willow riparian is present along Arastradero Creek. The amount of vegetation that will be
trimmed represents a minor amount of the riparian zone, and will not result in the permanent
removal of riparian habitat. Adverse effects to arroyo willow riparian are not expected.
Measures to protect wetland values from mowing and grazing are recommended (see measure
BIO-8).
Friend of Foothills Plants of Concern (see Table 3 in Appendix A) are not rare, but are of local
value in Foothills Park. These plants could be impacted by vegetation management activities
under the fire management plan update. Mitigation to reduce the impacts to these species is
recommended (see measure BIO-9).
Erosion. Maymen Rocky Fine Sandy Loam Eroded, and Maymen Fine Sandy Loam Eroded are
located on approximately one and a half miles of the P.A. 1 treatment approximately 2 miles east
of the Page Mill Road and Skyline Boulevard intersection. The P.A. 1 evacuation treatment,
which passes through Monte Bello and Los Trancos Open Space Preserves, contains interspersed
woodland and grassland and would be subject to vegetation trimming and no ground disturbance.
The Los Gatos-Maymen soils are the most extensive and are found in Foothills Park and
Pearson-Arastradero Preserve. At Foothills Park the soil is found on evacuation, firefighter
safety, containment, ignition and defensible space treatments (F.E. 1, F.E. 3, F.E. 5, F.F.1, F.F. 2,
F.F. 3, F.F. 4, F.C. 1, F.C. 2, F.C. 3, F.C. 6, F.D. 4, F.D. 6, F.I. 1, F.I. 2, F.I. 3). At Pearson-
Arastradero Preserve the soil is found on prescribed burn, containment, and defensible space
treatments (ARx2, A.C. 5, A.C. 10, A.D. 3). These treatments are located in grassland,
woodland, chaparral, and riparian/aquatic habitats.
The Fire Management Plan includes best management practices to prevent erosion, including
those labeled as BMP-2, BMP-3, BMP-6, BMP-7 and BMP-8 in section 6.0 below. Mostly,
however, the plan does not require soil disturbance, and leaves a protective vegetative cover over
soils. The exception may be the 100-ft defensible space around structures. Significant impacts
associated with erosive soils are not expected to result from implementation of the plan.
Invasive Plant Species. As described in section 4.0 above, invasive plants pose an existing
management problem in Pearson-Arastradero Preserve and Foothills Park. The Foothills Fire
Management Plan Update proposes the use of hand labor, mowing and grazing with goats. The
goats, workers and vehicles can carry seed of invasive plants and either introduce new invasive
species to the Park and Preserve, or foster the spread of those species already present. The fire
management plan includes best management practices to guard against the spread of invasive
plant species (see BMP-5 and BMP-15 under 6.0, below). Measures to prevent the spread of
Sudden Oak Death are also recommended in BIO-10. The fire management plan provides the
opportunity to remove invasive exotic species on a regular basis since it is a regular vegetation
management program. The plan also recommends that areas infested with invasive species not
be trimmed at seed set in order to reduce the amount of seed that is spread around by
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management activities. Seed set for the invasive broom species known in the Park and Preserve
is in the spring and summer, and trimming could occur in other seasons. However, yellow star
thistle blooms between May and October, and would set seed during the time that it is necessary
to mow the grasslands where it occurs. The plan provides for controlled burn as another method
to control the worst infestation of yellow star thistle in Arastradero Preserve. The plan would
neither improve nor exacerbate the effects the existing fire management methods have on yellow
star thistle in Foothills Park. No significant impacts are expected as long as the best
management practices incorporated into the plan and the additional measures for Sudden Oak
Death are implemented.
5.0 Mitigation
The Palo Alto Foothills Fire Management Plan Update includes an extensive list of best
management practices that are to be incorporated into the implementation of the Plan. These are
listed in Section 5.1, below. These practices will prevent many biological impacts. Section 5.2
includes a list of additional measures and suggested modifications to the best management
practices to ensure the Plan avoids significant biological impacts. The Best Management
Practices that should be modified are listed below as BMP-4, BMP-5, BMP-13, and BMP-16.
5.1. Best Management Practices Included in the Palo Alto Foothills Fire Management
Plan Update
The Plan lists best management practices under the heading of each treatment method (eg., hand
labor, mechanical treatment, etc.). The following list combines all of the practices and assigns a
number to each.
BMP-1: Provide or confirm adequate training, experience, and oversight to ensure that
personnel are familiar with the treatment method operations and planning, site conditions,
potential and identified sensitive resources, and the identification of specific environmental
features or conditions that must be avoided.
BMP-2: Avoid treatment actions during conditions that may affect water or run-off including
during storms, periods of precipitation, or immediately following severe weather. In addition,
avoid scheduling any treatment actions during seasons with significant predicted precipitation.
Cease operations or postpone planned operations including movement of vehicles or equipment
during precipitation conditions that may combine with vehicle activity to cause damage to roads,
trails, or adjacent land areas.
BMP-3: Avoid excessive foot or vehicle traffic on slopes, unimproved or non-designated trails,
or outside of preexisting roads or access points.
BMP-4: Inspect areas for nesting birds to determine if activity should be postponed or adjusted
by the establishment of a buffer area. This measure should be modified as described in measure
BIO-1.
BMP-5: Clean all tools and equipment following actions and prior to movement into new
environmental areas to prevent the spread of invasive or non-native plants.
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BMP-6: Plan treatment actions and equipment selection to minimize damage or alterations to
existing soils. Determine locations of potentially erosive soils prior to treatment. Restrict
operations that may adversely affect sensitive soil systems such as serpentine soil areas, erosion
prone soils, or riparian zones. Restriction may include using road-based operations only, and
avoiding riparian set-backs established by regulatory agencies.
BMP-7: Maintain a buffer of 25-50 feet between operations and water bodies or designated
riparian areas. Avoid crossing drainage channels, run-off areas, or dry streambeds. Install and
manage run-off barriers for rainwater in all treatment and operating areas. Restrict mechanical
removal of trees to areas further than 50 feet from drainage channels.
BMP-8: Restrict vehicle traffic to preexisting roads or pre-planned access points based on
equipment size and operations. Limit transport and support equipment to existing roads. Limit
heavy equipment use to slopes less than 30%. Install erosion control measures on all vehicle
roads and traffic areas.
BMP-9: Maintain strict monitoring and control of fueling and maintenance operations. All
maintenance actions that may produce spills should be executed in areas with secondary
containment protection, away from any water bodies or drainage areas. Clean up of all spills
should be done on-site, with materials ready for use. Inspection of equipment for new leaks and
mechanical problems should be performed daily, prior to operations.
BMP-10: Plan operations around expected seeding conditions of targeted species (either prior to
or sufficiently afterwards) to ensure efficiency of treatment action.
BMP-11: Cease actions during periods of high fire danger or during red flag conditions. Ensure
that all mechanical equipment have approved spark arrestors and comply with California Public
Resources Code (PRC) sections 4431, 4435, 4442, and 4437 to limit potential for ignition of
incidental fires.
BMP-12: Maintain on-site fire suppression resources to include shovel, water pump, fire
extinguisher, and two-way radio or communications for fire reporting.
BMP-13: One of the primary adverse impacts of grazing is over-grazing and the resulting
exposure of bare ground. Over-grazing can increase the potential for soil erosion, water run-off
and drainage, elimination of native plant species, and spread of non-native plants and weeds.
Prepare a grazing management plan by a certified range specialist that specifies goals, stocking
levels, grazing periods, installation of range improvements (such as water sources) to evenly
distribute utilization of feed, and monitoring and performance criteria.
BMP-14: Develop a site-specific annual grazing plan that includes project-level plans for
sticking, timing, and resource management goals.
BMP-15: Prior to introduction, all animals should be quarantined and fed weed-free forage to
limit spread of invasive or unwanted plant species as well as prevent spread of livestock diseases.
BMP-16: Limit grazing to non-riparian areas.
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BMP-17: Develop a smoke management plan describing desired outcomes and specific actions
for onsite personnel including a test burn, continual evaluation of smoke dispersal, monitoring of
wind patterns, and monitoring of potential visibility impacts to primary roads and highways.
BMP-18: Develop public safety plans to be executed throughout the prescribed burn cycle
including press and information releases, signs and notifications, patrols on roads and access
points, and development of a fire contingency plan.
BMP-19: Maintain a buffer between the prescribed burn area and water bodies or drainage into
riparian zones. Buffers should be a minimum of 25 feet for 5% slopes, 75 feet for 5-10% slopes,
and 250 feet for 10% or greater slopes. No prescribed fires should be ignited near streams or in
riparian zones.
BMP-20: Plan the prescribed burn to minimize post-fire erosion into water bodies and drainages
through natural barriers, proper construction of fire lines along contours, and proper erosion
control barrier deployment. Minimize prescribed burning in areas with highly erodible soils.
BMP-21: Cultural and social sites and structures shall be excluded from burn area through
planning, hand-lines, or other fire protection operations. On-site personnel will be briefed on
locations and features of cultural or social sites to include incident command or response
personnel. Avoid prescribed burns in areas with utility infrastructure, existing property or
structures, or archeological sites.
BMP-22: Manage fuel moisture through pre-fire assessment and potential fuel modification.
Prior to prescribed burn, remove ladder fuels into the tree canopy to increase safety and reduce
torching.
BMP-23: Conduct prescribed burns only on designated burn days as authorized by BAAQMD.
BMP: 24: The application of herbicides for vegetation treatment should focus on the goal of
applying the least amount of chemical required to achieve a desired outcome, consistent with the
City of Palo Alto’s Integrated Pest Management policy.
BMP-25: Herbicide is only applied per a prescription prepared by a Pesticide Control Advisor
licensed in that county, and applied by a licensed Pesticide Control Applicator.
BMP-26: Develop public safety plans to be executed throughout the treatment cycle including
press and information releases, signs and notifications, and fencing or area restrictions.
BMP-27: Develop a spill contingency plan and maintain strict monitoring and control of
operations. Clean up of all spills should be done on-site, with materials ready for use.
BMP-28: Chemical treatments within habitat of California Red-legged Frog should be
conducted according to U.S. District Court injunction and order covering 66 pesticides (Oct
2006) and subsequent EPA effects determinations.
BMP-29: Avoid treating areas adjacent to water bodies, riparian areas, and primary drainage
access. Follow all herbicide labels and directions in determining applications near water
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resources or riparian habitats. Limit aerial application to greater than 100 feet from water
resources. Limit ground and hand application to greater than 50 feet.
BMP-30: Avoid treating areas used for livestock operations or intended as grazing areas.
5.2. Additional Biological Mitigation Measures or Modifications to BMPs
BIO-1: Vegetation removal in any vegetation type from February 15 to August 31 requires a
survey for nesting birds by a qualified biologist2 or by park staff trained to do so by a qualified
biologist and avoiding removal of nests in active use. If raptor nests are detected, a buffer area
will need to be established around the nest in consultation with the California Department of Fish
and Game. The buffer may be 250 feet.
BIO-2: Vegetation removal in areas of serpentine soil, oak woodland, chaparral, coastal scrub
and riparian forest habitats requires a survey for rare plant species by a qualified biologist/
botanist prior to vegetation removal. Known rare plant locations should be treated in a way that
benefits the rare species. This may include limiting the area of treatment in order to provide a
buffer around the plant(s), or may include selectively trimming competitive vegetation adjacent
to the plant(s). Some species may benefit from disturbance; the specific actions to be taken
should be determined in consultation with a botanist. The plant survey needs to occur during the
bloom period. After surveys in the same locations over three separate years, subsequent surveys
are not necessary in that area unless a newly listed plant species could occur in the habitat. This
should be determined by consulting the California Department of Fish and Game.
BIO-3: Vegetation removal, including dead and downed debris, requires a survey for presence
of San Francisco dusky-footed woodrat by a qualified biologist or by park staff trained to
identify woodrat houses by a qualified biologist. If woodrat houses are found, disturbance
should be avoided and a minimum five-foot buffer should be provided around the house. If, for
public safety reasons, it is necessary to move the house, the process must be coordinated with the
California Department of Fish and Game. It is recommended that workers receive instruction
regarding woodrat houses prior to their start of work.
BIO-4: Prior to the removal of any tree that is 12 inches or more in diameter breast height, a
survey for perennial bat roosts and, during the breeding season from February 15 to August 31,
raptor nests shall be conducted by a qualified biologist or park staff trained by a qualified
biologist to identify these resources is required. If present, removal cannot continue without
CDFG guidance.
BIO-5: Discing within 500 feet of a lake, pond or creek, requires a biological survey to
determine impacts to California red-legged frog, California tiger salamander, San Francisco
garter snake and Western pond turtle and whether permits are required from the USFWS/CDFG.
BIO-6: Discing in grassland requires a pre-construction survey for American badger, California
red-legged frog and burrowing owl by a qualified biologist.
BIO-7: Trimming of coast live oaks shall follow the City’s Tree Ordinance (Title 8). Coast live
oak or Valley oaks that are 11.5 inches in diameter or more measured at 54 inches above grade
2 A “qualified biologist” is a person with demonstrated ability to identify special-status plant and/or animal species
in the San Francisco Bay Area.
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may not be removed without a permit, and may not be pruned such that more than 25 percent of
the crown is removed or the tree is left unbalanced.
BIO-8: Avoid wetlands mapped in Pearson-Arastradero Preserve when weed-whipping or
mowing. Modify the Fire Management Plan Best Management Practice that requires that a
grazing plan be prepared to include protection of drainages and wetlands from the impacts of
grazing animals.
BIO-9: For treatments in Foothills Park or on Page Mill Road along the Park border, a pre-work
survey for stands of locally important plants (see Table 3 in Appendix A) should be conducted,
and the plants avoided as long as it does not impair public safety. Field crews should be educated
about the sensitivity of these plant species.
BIO-10: In addition to BMP-5, it is recommended that measures be taken to clean equipment,
tires, and shoes to prevent the spread of Sudden Oak Death, and that any materials infected with
the disease be disposed of in accordance with State or County Agricultural Commission
guidelines. To reduce the possibility of spreading the disease, it is recommended that work not
be done in wet or muddy conditions, and that infested areas be avoided to the extent feasible.
Additional guidelines are available from the County Agricultural Commissioner.
6.0 Response to CEQA Checklist Biology Questions
a. Have a substantial adverse effect, either directly or through habitat modifications, on
any species identified as a candidate, sensitive, or special status species in local or regional
plans, policies, or regulations, or by the California Department of Fish and Game or U.S.
Fish and Wildlife Service?
With mitigation incorporated, the Foothills Fire Management Plan will not result in adverse
impacts to any special-status species. The special-status species that are known to occur in the
Foothills Fire Management Plan area are Steelhead, San Francisco dusky-footed woodrat, white-
tailed kite, arcuate bush mallow, and western leatherwood. Suitable habitat for several others
exists, but their presence has not been verified.
The mitigation measures that will prevent adverse effects to these species, primarily through
avoidance, include the following:
BIO-1: Vegetation removal in any vegetation type from February 15 to August 31 requires a
survey for nesting birds by a qualified biologist or by park staff trained to do so by a qualified
biologist and avoiding removal of nests in active use. If raptor nests are detected, a buffer area
will need to be established around the nest in consultation with the California Department of Fish
and Game. The buffer may be 250 feet.
BIO-2: Vegetation removal in areas of serpentine soil, oak woodland, chaparral, coastal scrub
and riparian forest habitats requires a survey for rare plant species by a qualified biologist/
botanist prior to vegetation removal. Known rare plant locations should be treated in a way that
benefits the rare species. This may include limiting the area of treatment in order to provide a
buffer around the plant(s), or may include selectively trimming competitive vegetation adjacent
to the plant(s). Some species may benefit from disturbance; the specific actions to be taken
should be determined in consultation with a botanist. The plant survey needs to occur during the
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bloom period. After surveys in the same locations over three separate years, subsequent surveys
are not necessary in that area unless there a newly listed plant species could occur in the habitat.
This should be determined by consulting the California Department of Fish and Game.
BIO-3: Vegetation removal, including dead and downed debris, requires a survey for presence
of San Francisco dusky-footed woodrat by a qualified biologist or by park staff trained to
identify woodrat houses by a qualified biologist. If woodrat houses are found, disturbance
should be avoided and a minimum five-foot buffer should be provided around the house. If, for
public safety reasons, it is necessary to move the house, the process must be coordinated with the
California Department of Fish and Game. It is recommended that workers receive instruction
regarding woodrat houses prior to their start of work.
BIO-4: Prior to the removal of any tree that is 12 inches or more in diameter breast height, a
survey for perennial bat roosts and, during the breeding season from February 15 to August 31,
raptor nests shall be conducted by a qualified biologist or park staff trained by a qualified
biologist to identify these resources is required. If present, removal cannot continue without
CDFG guidance.
BIO-5: Discing within 500 feet of a lake, pond or creek, requires a biological survey to
determine impacts to California red-legged frog, California tiger salamander, San Francisco
garter snake and Western pond turtle and whether permits are required from the USFWS/CDFG.
BIO-6: Discing in grassland requires a pre-construction survey for American badger, California
red-legged frog and burrowing owl by a qualified biologist.
BIO-7: Trimming of coast live oaks shall follow the City’s Tree Ordinance (Title 8). Coast live
oak or Valley oaks that are 11.5 inches in diameter or more measured at 54 inches above grade
may not be removed without a permit, and may not be pruned such that more than 25 percent of
the crown is removed or the tree is left unbalanced.
BIO-8: Avoid wetlands mapped in Pearson-Arastradero Preserve when weed-whipping or
mowing. Modify the Fire Management Plan Best Management Practice that requires that a
grazing plan be prepared to include protection of drainages and wetlands from the impacts of
grazing animals.
BIO-9: For treatments in Foothills Park or on Page Mill Road along the Park border, a pre-work
survey for stands of locally important plants (see Table 3 in Appendix A) should be conducted,
and the plants avoided as long as it does not impair public safety. Field crews should be educated
about the sensitivity of these plant species.
BIO-10: In addition to BMP-5, it is recommended that measures be taken to clean equipment,
tires, and shoes to prevent the spread of Sudden Oak Death, and that any materials infected with
the disease be disposed of in accordance with State or County Agricultural Commission
guidelines. To reduce the possibility of spreading the disease, it is recommended that work not
be done in wet or muddy conditions, and that infested areas be avoided to the extent feasible.
Additional guidelines are available from the County Agricultural Commissioner.
Foothills Fire Management Plan Biological Impact Assessment Page 46
TRA Environmental Sciences 1/8/2009
b. Have a substantial adverse effect on any riparian habitat or other sensitive natural
community identified in local or regional plans, policies, regulations or by the California
Department of Fish and Game or US Fish and Wildlife Service?
No. The amount of vegetation that will be trimmed represents a minor amount of the riparian
zone, and will not result in the permanent removal of riparian habitat. Adverse effects to arroyo
willow riparian are not expected. Measures to protect wetland values from mowing and grazing
are recommended (see measure BIO-8).
c. Have a substantial adverse effect on federally protected wetlands as defined by Section
404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological interruption, or other means?
With mitigation, the Fire Management Plan will have no adverse effect on wetlands. Wetlands
occur in Pearson-Arastradero Preserve and at Boronda Lake in Foothills Park. Implementation
of the Foothills Fire Management Plan will not result in the removal or filling of wetlands, and
will not affect their hydrology. Wetlands could be affected by the following treatments: A.E. 1
(Arastradero Road adjacent to the Preserve to be treated with mowing, grazing and hand labor),
A.Rx. 1 and A.Rx.2 (prescribed fire in the middle of the Preserve), A.C.3 (grazing the grassland
on the parking lot side of the Preserve), and A.C.11 (mowing Meadow Lark to Juan Bautista
Trail). Measure BIO-8 is proposed to be included in the Fire Management Plan, which is to
avoid mowing or weed-whipping wetlands, and to incorporate wetland protection measures in
the grazing management plan required in the fire management plan.
d. Interfere substantially with the movement of any native resident or migratory fish or
wildlife species or with established native resident or migratory wildlife corridors, or
impede the use of native wildlife nursery sites?
The Foothills Fire Management Plan does not require activities in stream courses that would
impede any fish passage. It does not require the construction of any structures that would block
wildlife movement.
e. Conflict with any local policies or ordinances protecting biological resources, such as a
tree preservation policy or ordinance?
Activities proposed in the Foothills Fire Management Plan are subject to the City of Palo Alto’s
municipal code with regard to tree removal. Trimming or removal of coast live oak trees are
subject to the requirements of Title 8, which include limits on trimming to less than 25 percent of
the tree canopy and that the trimming not unbalance the tree. The Fire Management Plan may
result in the removal or trimming of protected trees. Measure BIO-7 is included to require that
trimming follow the tree preservation ordinance. With this measure included, the Fire
Management Plan will comply with local ordinances protecting biological resources.
f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan?
The Foothills Fire Management Plan is not within an area subject to a Habitat Conservation Plan
or any similar approved planning document.
Foothills Fire Management Plan Biological Impact Assessment Page 47
TRA Environmental Sciences 1/8/2009
7.0 References
California Department of Fish and Game. Rare and endangered species lists.
http://www.dfg.ca.gov/biogeodata/cnddb/plants_and_animals.asp. Viewed on October 27, 2008.
California Department of Fish and Game. California Natural Diversity Database. Rare plant,
animal and communities. Report created on October 27, 2008.
California Department of Fish and Game. Fully protected species list.
http://www.dfg.ca.gov/wildlife/species/t_e_spp/fully_pro.html. Viewed on October 27, 2008.
California Oak Mortality Task Force. www.suddenoakdeath.org. Viewed on December 12,
2008.
Cal-IPC. 2008. www.cal-ipc.org . Viewed on November 29, 2008.
Cal-IPC. 2008a. http://www.cal-
ipc.org/ip/management/plant_profiles/Genista_monspessulana.php. Viewed on November 29,
2008.
Cal-IPC. 2008b. http://www.cal-
ipc.org/ip/management/plant_profiles/Carduus_pycnocephalus.php. Viewed on November 29,
2008.
Cal-IPC. 2008c. http://www.cal-ipc.org/ip/management/plant_profiles/Centaurea_solstitialis.php.
Viewed on November 29, 2008.
California Native Plant Society. Online Inventory of rare and endangered plants.
http://cnps.web.aplus.net/cgi-bin/inv/inventory.cgi. Viewed on October 27 2008.
Cal-IPC. 2006. California Invasive Plant Inventory. Cal-IPC Publication 2006-02. California
Invasive Plant Council: Berkeley, CA.
City of Palo Alto. 2008. Palo Alto Foothills Fire Management Plan Update: Wildland Fire Risk
Assessement and Mititgation Program. Administrative Draft. Wildland Resource Management,
Inc.
National Marine Fisheries. Critical Habitat for endangered species.
http://www.nmfs.noaa.gov/pr/species/criticalhabitat.htm. Viewed on October 27, 2008.
Soil Survey for Santa Clara County. 1968. Natural Resources Conservation Service, United
States Department of Agriculture.
Soil Survey Staff, Natural Resources Conservation Service, United States Department of
Agriculture. Official Soil Series Descriptions [Online WWW]. Available URL:
“http://soils.usda.gov/technical/classification/osd/index.html” [Accessed 10 February 2008].
USDA-NRCS, Lincoln, NE.
Foothills Fire Management Plan Biological Impact Assessment Page 48
TRA Environmental Sciences 1/8/2009
United States Fish and Wildlife Service: Sacramento
http://www.fws.gov/sacramento/es/spp_list.htm. Viewed on October 27, 2008.
Persons Consulted
Alan Launer, Campus Biologist, Stanford University.
Sherri Lubin, Acterra. Stewardship Director. (Acruate bush mallow locations.)
William Reed. Natural Resources Conservation Service. Santa Clara Soil Survey Project Leader.
(Soil Survey data.)
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 49
TRA Environmental Sciences 1/8/2009
Appendix A. Tables
Table 1. Special-status Species Considered in the Biological Impact Assessment ....................................50
Table 2 Bat Species of Concern on the San Francisco Peninsula...............................................................62
Table 3 Non-listed Native Plants of Concern in Foothills Park..................................................................63
Table 4. Fire Plan Treatments, Habitats Affected, and Protective Measures..............................................67
Table 5. Special-status Species by Habitat Type and Treatment Location, with Protection Measures......74
Table 6. Change in Area Impacted under the Fire Management Plan........................................................78
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 50
TRA Environmental Sciences 1/8/2009
Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
Invertebrates
Bay checkerspot
butterfly
(Euphydryas editha
bayensis)
FT A medium-sized butterfly whose larvae are
dependent on dwarf plantain and owls
clover. It is mostly found within serpentine
grassland habitat.
Pearson-Arastradero - HP
Habitat is present but the serpentine
grassland areas are to small to support
a population.
Foothills – A. Habitat is not present.
Highly Unlikely. The closest
population is located in Edgewood
County Park 6.3 air miles north
(CNDDB 2008).
Leech’s skyline
diving beetle
(Hydroporus
leechi)
None, but
considered
special status
by the CDFG
Aquatic scavenger found in still pools and
ponds.
Pearson-Arastradero - HP
Habitat is present at Arastradero Lake
and John Sobey Pond.
Foothills – HP. Habitat is present at
Boranda Lake.
Highly Unlikely. The closest
population is located in Edgewood
County Park 6.3 air miles north
(CNDDB 2008).
Zayante band-
winged grasshopper
(Trimerotropis
infantilis)
FE Occurs in open sandy areas with sparse, low
annual and perennial herbs on high ridges
with sparse ponderosa pine.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present.
Occurs only in the sandhills of Santa
Cruz County greater than five miles
from the site (CNDDB 2008).
Amphibians
California red-
legged frog
(Rana aurora
draytonii)
FT/CSSC Lowlands and foothills in or near permanent
sources of deep water with dense, shrubby
or emergent riparian vegetation. Requires
11-20 weeks of permanent water for larval
development.
Pearson-Arastradero - HP
Potential breeding habitat at Los
Trancos Creek, and its tributaries,
John Sobey Pond and Arastradero
Creek
Foothills – HP. Potential breeding
habitat at Boronda Lake. Foraging
habitat in riparian zones, grassland,
and oak woodland above Los Trancos
Creek and tributaries.
Closest known occurrence is 1.35 air
miles to the northeast at the
confluence of Matadero and Deer
creeks (CNDDB 2008).
California tiger
salamander
(Ambystoma
californiense)
FT/CSSC The California Tiger Salamander can grow
to a length of about 8–10 inches (20–25 cm)
and have black and have yellow or cream
spots; larvae are greenish-grey in color. It
depends on water for reproduction,
Pearson-Arastradero - HP
Breeding habitat may occur in the
“bowl” near the unnamed tributary to
Los Trancos Creek.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 51
TRA Environmental Sciences 1/8/2009
Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
therefore its habitat is limited to the vicinity
of fishless vernal pools or similar water
bodies.
Foraging habitat present at John
Sobey Pond and Arastradero Lake
Foothills – HP
Foraging habitat present at Boronda
Lake.
Not likely to occur. No known
records after various surveys. Closest
recorded population at Lake Lagunita
2.4 miles to the north of Pearson-
Arastradero Reserve (CNDDB 2008).
Birds
Golden Eagle
(Aquila chrysaetos)
CDFG – fully
protected
species
Uses rolling foothills and mountain terrain,
wide arid plateaus deeply cut by streams
and canyons, open mountain slopes, and
cliffs and rock outcrops. Eats mostly rabbits
and rodents; also takes other mammals,
birds, reptiles, and some carrion.
Pearson-Arastradero - HP
May utilize habitat mosaic for
foraging. No breeding habitat
available.
Foothills – HP
May utilize habitat mosaic for
foraging. No breeding habitat
available.
Tricolored
Blackbird
(Agelaius tricolor)
CSSC Common locally throughout Central Valley
and in coastal districts from Sonoma Co.
south. Breeds near fresh water, preferably in
emergent wetland with tall, dense cattails or
tules, but also in thickets of willow,
blackberry, wild rose, tall herbs. Feeds in
grassland and cropland habitats. Feeds
mostly on insects and spiders.
Pearson-Arastradero - HP
Breeding habitat available at
Arastradero Lake. Foraging habitat
occurs in the reserve grassland.
Foothills – HP
Breeding habitat available at Boronda
Lake. Foraging habitat occurs in the
reserve grassland.
Not likely to occur. The closest
recorded observation is greater than 5
miles southeast at the base of Calero
reservoir (CNDDB 2008).
Burrowing Owl
(Athene
cunicularia)
CSSC A yearlong resident of grassland habitats.
Eats mostly insects; also small mammals,
reptiles, birds, and carrion. Uses rodent or
other burrow for roosting and nesting cover.
Pearson-Arastradero - HP
Breeding and foraging habitat is
present.
Unlikely to occur. Closest siting is the
Palo Alto Municipal Airport 5.4 miles
northeast (CNDDB 2008).
Foothills – A. Habitat is not present
on-site. Site is to steep and out of the
elevation range for the species.
Marbled Murrelet
(Brachyramphus
marmoratus)
FT Breeds in coniferous forests near coasts,
nesting on large horizontal branches high up
in trees. Winters at sea.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 52
TRA Environmental Sciences 1/8/2009
Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
Northern Harrier
(Circus cyaneus)
CSC Mostly found in flat, or hummocky, open
areas of tall, dense grasses, moist or dry
shrubs, and edges for nesting, cover, and
feeding. Frequents meadows, grasslands,
open rangelands, desert sinks, fresh and
saltwater emergent wetlands; seldom found
in wooded areas. Feeds mostly on voles and
other small mammals, birds, frogs, small
reptiles, crustaceans, insects, and, rarely on
fish. Known to occur in the grasslands
within the city limits. Breeds in open fields
and meadows.
Pearson-Arastradero - HP
Foraging and breeding habitat
present.
Foothills – HP
Foraging and breeding habitat
present.
Yellow warbler
(Dendroica
petechia)
CSSC Usually found in riparian deciduous habitats
in summer: cottonwoods, willows, alders,
and other small trees and shrubs typical of
low, open-canopy riparian woodland. Also
breeds in montane shrubbery in open
conifer forests. In migration, visits
woodland, forest, and shrub habitats. Mostly
eats insects and spiders.
Pearson-Arastradero - HP
Foraging and breeding habitat
available in the Arastradero Creek
and unnamed tributary riparian
corridors.
Foothills – HP
Foraging and breeding habitat
available in the Buckeye Creek
riparian corridor.
White-tailed Kite
(Elanus leucurus)
CDFG – fully
protected
species
Uses herbaceous lowlands with variable tree
growth and dense population of Voles.
Substantial groves of dense, broad-leafed
deciduous trees used for nesting and
roosting. Preys mostly on voles and other
small, diurnal mammals, occasionally on
birds, insects, reptiles, and amphibians.
Forages in undisturbed, open grasslands,
meadows, farmlands and emergent
wetlands. Known to occur throughout the
town in all habitats mentioned here.
Pearson-Arastradero - HP
Foraging and breeding habitat
present.
Foothills – HP
Foraging and breeding habitat
present.
Saltmarsh common
yellowthroat
(Geothlypis trichas
sinuosa)
CSSC Resident of the San Francisco bay region, in
fresh and salt water marshes. Requires
thick, continuous cover down to water
surface for foraging; tall grasses, tule
patches, willows for nesting.
Pearson-Arastradero - HP
Foraging and breeding habitat
available at Arastradero Lake, John
Sobey Pond and in the riparian
corridors associated with Arastradero
Creek.
Foothills – HP
Foraging and Breeding habitat
available at Boronda Lake and in the
riparian corridors of Buckeye Creek.
Closest known occurrence is 3.0 miles
to the northwest at Searsville Lake
(CNDDB 2008).
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 53
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Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
Loggerhead Shrike
(Lanius
ludovicianus)
CSSC A common resident and winter visitor in
lowlands and foothills throughout
California. Prefers open habitats with
scattered shrubs, trees, posts, fences, utility
lines, or other perches. Eats mostly large
insects; also takes small birds, mammals,
amphibians, reptiles, fish, carrion, and
various other invertebrates.
Pearson-Arastradero - HP
Foraging and breeding habitat
available on-site in the grasslands and
oak woodland.
Foothills – HP
Foraging and breeding habitat
available on-site in the grasslands,
mixed evergreen forest and oak
woodland savannah.
Fish
Steelhead - Distinct
Population
Segment
(Oncorhynchus
mykiss irideus)
FT (CH) The Central California Coast Distinct
Population Segment extends from the
Russian River in the north to Soquel Creek
in the south.
Pearson-Arastradero – A. Habitat is
not present.
Foothills – A. Habitat is not present.
* Present in Los Trancos Creek along
evacuation route F.E6 and the
southern Foothills Park border.
Reptiles
San Francisco
garter snake
(Thamnophis
sirtalis tetrataenia)
FE/SE Vicinity of freshwater marshes, ponds, and
slow moving streams. Prefers dense cover
and water depths of at least one foot.
Upland areas near water are important.
Pearson-Arastradero - HP
Habitat present on-site at Arastradero
Lake, John Sobey Pond and
Arastradero Creek.
Foothills – HP
Habitat present at Boronda Lake and
Buckeye Creek.
Western pond turtle
(Actinemys
marmorata)
CSSC An aquatic turtle of ponds, marshes, rivers,
streams & irrigation ditches with aquatic
vegetation. WPT’s require basking sites
with suitable (sandy banks or grassy open
fields) upland habitat for egg-laying.
Pearson-Arastradero – HP
Habitat present on-site at Arastradero
Lake, John Sobey Pond and
Arastradero Creek.
Foothills – HP
Habitat present at Boronda Lake and
Buckeye Creek.
Closest recorded population is 3.0
miles to the northwest at Searsvillle
Lake (CNDDB 2008).
Mammals
Pallid bat
(Antrozous
pallidus)
CSSC Takes a wide variety of insects and
arachnids, including beetles, grasshoppers,
cicadas, moths, spiders, scorpions, and
Jerusalem crickets. Prefers rocky outcrops,
cliffs, and crevices with access to open
habitats for foraging. Very sensitive to
disturbance of roosting sites. Such sites are
essential for metabolic economy, juvenile
Pearson-Arastradero – HP
Foraging habitat is present in the
grassland. No roosting habitat
available.
Foothills – HP
Small rocky outcrops may provide
roosting habitat. Foraging habitat
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 54
TRA Environmental Sciences 1/8/2009
Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
growth and as night roosts to consume prey. present in the grassland.
Ringtail
(Bassaricus
astutus)
CSSC Uncommon and highly secretive.
Nocturnal. Dens in rock outcrops and tree
hollows. Eats small mammals, birds,
reptiles, amphibians, carrion, and nuts and
berries. Has a home range as large as 336
acres.
Pearson-Arastradero - HP
Den sites are available in oak
woodland and riparian habitats.
Foraging available in all habitats.
Foothills – HP
Den sites are available in oak
woodland, mixed evergreen, and
riparian habitats. Foraging available
in all habitats.
Western red bat
(Lasiurus
blosevillii)
CSSC Roosts primarily in trees, less often in
shrubs in edge habitats adjacent to streams,
fields, or urban areas. Preferred roost sites
are protected from above, open below, and
located above dark ground-cover. Such sites
minimize water loss.
Pearson-Arastradero - HP
Roosting habitat available in oak
woodland, riparian, and edge habitats.
Foraging available in all habitats.
Foothills – HP. Roosting habitat
available in oak woodland, mixed
evergreen and riparian. Foraging
available in all habitats.
American badger
(Taxidea taxus)
CSSC Most abundant in drier open stages of most
shrub, forest, and herbaceous habitats with
friable soils. Needs sufficient food source
(mostly burrowing rodents) and open,
uncultivated ground.
Pearson-Arastradero - HP
Foraging and burrow habitat available
throughout the whole site.
Foothills – HP. Foraging and burrow
habitat available throughout the whole
site.
Hoary bat (Lasiurus
cinereus)
None, but
considered
special status
by the CDFG
Prefers open habitats or habitat mosaics
with access to trees for cover and open areas
or habitat edges for feeding. Roosts in
dense foliage of medium to large trees,
feeds primarily on moths. Requires water.
Pearson-Arastradero – HP
Foraging habitat present throughout
the site. Roosting habitat is available
in riparian and oak woodland.
Foothills – HP
Foraging habitat available throughout
the site. Roosting habitat available in
riparian, oak woodland, and mixed
evergreen.
Fringed myotis
(Myotis
thysanodes)
None, but
considered
special status
by the CDFG
Occurs in a wide variety of habitats.
Optimal habitats are pinyon-juniper, valley
foothill hardwoods, and hardwood-conifer.
Uses caves, mines, building or crevices for
maternity colonies and roosts.
Pearson-Arastradero - HP
Roosting available in the structures
on-site. Foraging available throughout
the site.
Foothills – HP
Roosting available in the structures
on-site. Foraging available throughout
the site.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 55
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Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
San Francisco
dusky-footed
woodrat
(Neotoma fuscipes
annectens)
CSSC Generalist herbivores, they consume a wide
variety of nuts and fruits, fungi, foliage and
some forbs. Dusky-footed woodrats are
highly arboreal; evergreen or live oaks and
other thick-leaved trees and shrubs are
important habitat components for this
species. Houses typically are placed on the
ground against or straddling a log or
exposed roots of a standing tree and are
often located in dense brush. Houses also
are placed in the crotches and cavities of
trees and in hollow logs. Known to occur in
scrubby and forested habitat throughout the
town.
Pearson-Arastradero - HP
Habitat present in chaparral, mixed
evergreen and oak woodland.
Foothills – HP
Habitat present in chaparral, mixed
evergreen and oak woodland.
Plants
San Mateo thorn-
mint
(Acanthomintha
duttonii)
FE/SE, CNPS
1B
Annual herb found in serpentine areas of
chaparral, valley and foothill grassland,
coastal scrub. 50 – 300 meters. Blooms
April-July.
Pearson-Arastradero - HP
Habitat is present at AC4 and AC7.
Highly Unlikely. The closest
population is located in Edgewood
County Park 6.3 air miles north
(CNDDB 2008).
Foothills – A. Habitat is not present.
Franciscan onion
(Allium peninsulare
var. franciscanum)
CNPS 1B Perennial bulbiferous herb found in valley
and foothill grassland and cismontane
woodland. Often in serpentine, clay, or
volcanic soils. 100 – 300 meters. Blooms
May-June.
Pearson-Arastradero - HP
Habitat present in grasslands.
Foothills – HP
Habitat is present in grasslands.
Slender silver moss
(Anomobryum
julaceum)
CPNS 2 Broadleaved upland forest, lower montane
coniferous forest, North Coast coniferous
forest/damp rock and soil on outcrops,
usually roadcuts; 100 – 1000 meters.
Pearson-Arastradero – A. Habitat is
not present.
Foothills – A. Habitat is not present.
Anderson’s
manzanita
(Arctostaphylos
andersonii)
CNPS 1B Broadleaved upland forest, chaparral, north
coast coniferous forest. Open sites,
redwood forest. 180-800m. Blooms
November-April.
Pearson-Arastradero - HP
Habitat present in chaparral.
Foothills – HP
Habitat present in chaparral.
Highly unlikely. Known from fewer
than 15 occurrences in the Santa Cruz
Mountains (CNDDB 2008).
Schreiber’s
manzanita
(Arctostaphylos
glutinosa)
CNPS 1B Closed-cone coniferous forest,
chaparral/diatomaceous shale; 170-685
meters. Blooms November – April.
Pearson-Arastradero - HP
Habitat present in chaparral.
Foothills – HP
Habitat present in chaparral.
Highly unlikely. Known from fewer
than 10 occurrences in Santa Cruz
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 56
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Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
County (CNDDB 2008).
Kings mountain
manzanita
(Archtostaphylos
regismontana)
CNPS 1B Perennial evergreen shrub found on granite
or sandstone outcrops in chaparral,
coniferous and evergreen forests. 305 – 730
meters. Blooms March-April.
Pearson-Arastradero - HP
Habitat present in chaparral.
Foothills – HP
Habitat present in chaparral and
mixed evergreen.
Highly unlikely. Closest known
occurrence is greater than five miles
from the site at Teague Hill Open
Space Preserve at Summit Springs
Road in Redwood City (CNDDB
2008).
Bonny Doon
manzanita
(Archtostaphylos
silvicola)
CNPS 1B Chaparral, closed-cone coniferous forest,
lower montane coniferous forest/inland
marine sands; 120-600 meters. Blooms
February – March.
Pearson-Arastradero - HP
Habitat present in chaparral.
Foothills – HP
Habitat present in chaparral.
Highly unlikely. Known from fewer
than 20 occurrences greater than five
miles from the site in the Santa Cruz
County (CNDDB 2008).
Alkali milk-vetch
(Astragalus tener
var. tener)
CNPS 1B Playas, valley and foothill grassland (adobe
clay), vernal pools/alkaline; 1-60 meters.
Blooms March – June. Last collection
1959.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present.
There are no alkaline or adobe clay
soils present on site.
Santa Cruz Cypress
(Callitropsis
abramsiana)
FE/SE,
CNPS 1B
Closed-cone coniferous forest, chaparral,
lower montane coniferous forest/sandstone
or granitic; 280-800 meters.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – HP
Habitat is present in chaparral.
Highly unlikely. Known from fewer
than 20 occurrences greater than five
miles from the site in Santa Cruz
County (CNDDB 2008).
Santa Cruz
mountain
pussypaws
(Calyptridium
parryi var. hesseae)
CNPS 1B Chaparral, cismontane woodland; 305 –
1115 meters. Blooms May – July.
Pearson-Arastradero - A
Habitat is not present.
Foothills – HP
Habitat is present in chaparral.
Congdon’s tarplant
(Centromadia
parryi ssp.
congdonii)
CNPS 1B Valley and foothill grassland (alkaline); 1-
230 meters. Blooms June – November.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present
on-site.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 57
TRA Environmental Sciences 1/8/2009
Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
Ben Lomond
spineflower
(Chorizanthe
pungens var.
hatwegiana)
FE, CNPS 1B Lower montane coniferous forest (maritime
pondersa pine sandhills); 90 – 610 meters.
Blooms April – July. Known from sandhill
parklands in the Santa Cruz Mtns.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present.
Franciscan thistle
(Cirsium
andrewsii)
CNPS 1B Occurs within coastal bluff scrub,
broadleaved upland forest, and coastal
scrub. Sometimes found on serpentine
seeps.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present.
Crystal Springs
fountain thistle
(Cirsium fontinale
var. fontinale)
FE, SE,
CNPS 1B
Chaparral (openings), valley and foothill
grassland/serpentinite seeps; 90 – 175
meters. Blooms June – October. Known
from four occurrences in the vicinity of
Crystal Springs Reservoir.
Pearson-Arastradero – HP
Foothills – A. Habitat is not present.
San Francisco
collinisia
(Collinisia
multicolor)
CNPS 1B Moist shady woodland, associated with
California buckeye, honeysuckle, ferns,
coast live oak, poison oak. Known from
Edgewood Natural Preserve. Blooms
March-May.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present.
Norris’ beard moss
(Didymodon
norrisii)
CNPS 2 Cismontane woodland, lower montane
coniferous forest/intermittently mesic, rock;
600 – 1700 meters.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present.
Western
leatherwood
(Dirca
occidentalis)
CNPS 1B Broad-leafed upland forest, chaparral,
closed-cone coniferous forest, cismontane
woodland, north coast forest, riparian forest
and woodland. On brushy slopes, mesic
sites; mostly in mixed evergreen & foothill
woodland communities. 30-550m.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – P. Habitat is not present.
Found along Steep Hollow Trail
San Mateo wooly
sunflower
(Eriophyllum
latilobum)
FE, SE,
CNPS 1B
Cismontane woodland (serpentinite, often
on roadcuts); 45 – 150 meters. Blooms May
– June.
Pearson-Arastradero – HP.
Habitat is present at AC4 and AC7.
Highly unlikely. Known for only one
occurrence (CNPS 2001).
Foothills – A. Habitat is not present.
Fragrant fritillary
(Fritillaria liliacea)
CNPS 1B Perennial bulbiferous herb found in coastal
scrub, valley and foothill grassland, coastal
prairie. Often on serpentine; various soils
reported though usually clay, in grassland.
3-410m. Blooms February-April
Pearson-Arastradero – A. Habitat is
not present.
Foothills – A. Habitat is not present.
Marin Western Flax
(Hesperolinon
congestum)
FT, ST,
CNPS 1B
Annual herb found in chaparral, valley and
foothill grassland. In serpentine barrens and
in serpentine grassland and chaparral. 5-370
meters. Blooms April-July.
Pearson-Arastradero – HP
Habitat is present at AC4 and AC7.
Highly unlikely. Only fewer than 20
occurrences.
Highly Unlikely. The closest
population is located in Edgewood
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 58
TRA Environmental Sciences 1/8/2009
Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
County Park 6.3 air miles north
(CNDDB 2008).
Foothills – A. Habitat is not present.
Loma Prieta hoita
(Hoita strobilina)
CNPS 1B Chaparral, cismontane woodland, riparian
woodland/usually serpentinite, mesic; 30 –
600 meters. Blooms May – October.
Pearson-Arastradero – HP
Habitat is present at AC4 and AC7.
Highly unlikely.
Highly unlikely. Closest known
occurrence is greater than five miles
to the south in the Santa Teresa Hills
(CNDDB 2008).
Foothills – A. Habitat is not present.
Crystal Springs
lessingia
(Lessingia
arachnoidea)
CNPS 1B Annual herb found in coastal sage scrub,
valley and foothill grassland, cismontane
woodland. Grassy slopes on serpentine;
sometimes on roadsides. 60-200m. Blooms
July – October.
Pearson-Arastradero – HP
Habitat is present at AC4 and AC7.
Highly unlikely. Known from seven
occurrences near Crystal Springs
reservoir (CNDDB 2008).
Foothills – A. Habitat is not present.
Arcuate bush-
mallow
(Malacothamnus
arcuatus)
CNPS 1B Grows in gravelly alluvium in chaparral and
grassland. Also occurs on serpentine. 15 –
355 meters. Blooms April – September.
Pearson-Arastradero – P
Six locations within the reserve.
Foothills – HP
Habitat present in chaparral and
grassland.
Robust Monardella
(Monardella villosa
ssp. globosa)
CNPS 1B Chaparral (openings), cismontane
woodland, coastal scrub; 185 – 600 meters.
Blooms June – July.
Pearson-Arastradero - HP
Habitat present in chaparral.
Foothills – HP
Habitat present in chaparral and
mixed evergreen.
Kellman’s bristle
moss
(Orthotrichum
kellmanii)
CNPS 1B Chaparral, cismontane woodland,
sandstone, carbonate; 343 – 685 meters.
Pearson-Arastradero – A. No habitat
is present. Reserve is to low in
elevation.
Foothills – HP
Habitat present in chaparral and
mixed evergreen.
Dudley’s lousewort
(Pedicularis
dudleyi)
SR, CNPS 1B Perennial herb found in maritime chaparral,
cismontane woodland, and North Coast
coniferous forest. 60 – 900 meters. Known
from fewer than 15 locations. Occurs at
Edgewood County Park. Blooms April-
June.
Pearson-Arastradero - HP
Habitat is present in chaparral.
Foothills – HP
Habitat is present in chaparral.
Highly unlikely. Closest known
occurrence 6.3 air miles to the north
at Edgewood County Park (CNDDB
2008).
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 59
TRA Environmental Sciences 1/8/2009
Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
White-rayed
pentachaeta
(Pentachaeta
bellidiflora)
FE/SE Occurs within valley and foothill grasslands
on open, dry, and rocky slopes. Often found
on soils derived from serpentine bedrock.
35-620m.
Pearson-Arastradero – HP
Habitat present in grassland.
Not likely to occur. Only occurrence
is at Edgewood County Park 6.3 air
miles to the north.
Foothills – A. Habitat is not present.
Monterey pine
(Pinus radiata)
CNPS 1B Closed cone coniferous forest, cismontane
woodland; 25 – 185 meters. Found in only
three locations along the central coast.
Pearson-Arastradero - A. Habitat is
not present.
Foothills – A. Habitat is not present.
White-flowered
rein orchid
(Piperia candida)
CNPS 1B Perennial herb found in broadleafed upland
forest and coniferous forests, sometimes
serpentine. 30 – 1310 meters. Blooms
May-September.
Pearson-Arastradero - HP
Habitat present in riparian corridor.
Foothills – HP
Habitat present in mixed evergreen
and riparian corridor.
Found in adjacent Los Trancos Open
Space Preserve (CNDDB 2008).
San Francisco
popcorn-flower
(Plagiobothrys
diffuses)
SE, CNPS 1B Coastal prarie, valley and foothill grassland;
mesic; 60 – 360 meters. Blooms March -
June.
Pearson-Arastradero - HP
Habitat is present in grassland
Foothills – HP
Habitat is present in grassland.
Highly unlikely. The closest known
occurrence is greater than 5 miles
away in Santa Cruz County near Point
Año Nuevo State Park (CNDDB
2008).
San Francisco
campion
(Silene verecunda
ssp. verecunda)
CNPS 1B Perennial herb found in sandy areas of
coastal scrub, valley & foothill grassland,
coastal bluff scrub, chaparral, and coastal
prairie. 30 – 645 meters. Blooms March-
August.
Pearson-Arastradero - HP
Habitat present in grassland and
chaparral.
Foothills – HP
Habitat present in grassland and
chaparral.
Not likely to occur. Only occurrence
is at Edgewood County Park 6.3 air
miles to the north (CNDDB 2008).
Santa Cruz
microseris
(Stebbinsoseris
decipiens)
CNPS 1B Broad-leaved upland forest, closed-cone
coniferous forest, chaparral, coastal prarie,
coastal scrub, valley and foothill
grassland/open areas; sometimes
serpentinite; 10 – 500 meters. Blooms April
– May.
Pearson-Arastradero - HP
Habitat present in chaparral and
grassland.
Foothills – HP
Habitat present in chaparral, mixed
evergreen and grassland.
Highly unlikely. The closest known
occurrence is greater than 5 miles
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 60
TRA Environmental Sciences 1/8/2009
Table 1. Special-status Species Considered in the Biological Impact Assessment
Species name State/Federal
Status Habitat Habitat Present/Absent
away in Santa Cruz County near
Franklin Point (CNDDB 2008).
Communities
Northern maritime
chaparral
None, but
considered
special status
by the CDFG
Maritime chaparral contains plants adapted
to areas with cool, foggy summers.
Generally found on nutrient poor soils and
occurs on windward uplands and coastal
lowlands. Arctostaphylos and Ceanothus
species characterize the habitat.
Pearson-Arastradero - A. Community
is not present on-site.
Foothills – A. Community is not
present on-site.
Valley needlegrass
grassland
None, but
considered
special status
by the CDFG
Dominated by the perennial, tussock
forming purple needlegrass (Nasella
pulchra). Usually on fine-textured (often
clay) soils; moist or even waterlogged in
winter, but very dry in summer
Pearson-Arastradero – P
Restored purple needlegrass
grassland.
Foothills – A
Community is not present on-site.
Absent [A] - no habitat present and no further work needed. Habitat Present [HP] -habitat is, or may be present.
The species may be present. Present [P] - the species is present. Critical Habitat [CH] - project footprint is located
within a designated critical habitat unit, but does not necessarily mean that appropriate habitat is present.
Notes:
CNPS – California Native Plant Society (www.cnps.org)
List 1A: plants presumed extinct in California
List 1B: plants rare, threatened, or endangered in California and elsewhere
List 2: Plants rare, threatened, or endangered in California, but more common elsewhere
List 3: Plants about which we need more information – a review list
List 4: Plants of limited distribution – a watch list
Threat Ranks:
0.1 – seriously threatened in California (high degree/immediacy of threat)
0.2 – fairly threatened in California (moderate degree/immediacy of threat)
0.3 – not very threatened in California (low degree/immediacy of threats or no current threats known
CSSC – California Species of Concern
FE – Federal endangered (listed by the federal government as an endangered species)
FT – Federal threatened (listed by the federal government as a threatened species)
SE – State endangered (listed by the state of California as an endangered species)
ST – State threatened (listed by the state of California as a threatened species)
SR – State rare (listed by the state of California as a rare species)
References:
United States Fish and Wildlife Service: Sacramento http://www.fws.gov/sacramento/es/spp_list.htm. Viewed on
October 27, 2008.
California Native Plant Society. Online Inventory of rare and endangered plants. http://cnps.web.aplus.net/cgi-
bin/inv/inventory.cgi. Viewed on October 27 2008.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 61
TRA Environmental Sciences 1/8/2009
California Department of Fish and Game. Rare and endangered species lists.
http://www.dfg.ca.gov/biogeodata/cnddb/plants_and_animals.asp. Viewed on October 27, 2008.
California Department of Fish and Game. California Natural Diversity Database. Rare plant, animal and
communities. Report created on October 27, 2008.
National Marine Fisheries. Critical Habitat for endangered species.
http://www.nmfs.noaa.gov/pr/species/criticalhabitat.htm. Viewed on October 27, 2008.
California Department of Fish and Game. Fully protected species list.
http://www.dfg.ca.gov/wildlife/species/t_e_spp/fully_pro.html. Viewed on October 27, 2008.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 62
TRA Environmental Sciences 1/8/2009
Table 2 Bat Species of Concern on the San Francisco Peninsula
Bat Species Habits/Habitat Requirements
California myotis (Myotis
californicus)
Roosts alone or in groups typically in trees cavities, caves, and buildings.
Found over water, in forests, at edges of forests, and in open areas. Pups
usually born in July.
Mexican free-tailed
(Tadarida brasiliensis)
Colonial roosting typically in caves and building. Found in open areas,
forests, over water and near buildings. A characteristic musty odor can be
detected near their roosts. Pups born in the summer.
Western red (Lasiurus
blossevillii)
Roosts alone typically in the leaves of large trees and shrubs. Found in
forests, over water, in open areas, and in buildings. Pups born May-June.
Yuma (Myotis
yumanensis)
Maternal roosts are colonial; males have solitary roosts. Uses buildings and
caves for roosting. Found over water and near or in buildings. Pups born
May-July.
Pallid (Antrozous pallidus) Roosts in colonies in buildings and rock crevices, caves, mines, rock piles,
and tree cavities. Tend to choose roosts where they can easily retreat into
tight crevices when disturbed. Can be heard in the roost; roost has a faint
skunk-like smell. Summer and winter roosting sites are the same, but the
bats are more likely to roost singly or in pairs in the winter. Pups are born
April-June. Found in or near buildings, rock crevices, mines, and tree
cavities. Catches its prey on the ground or on leaves. Prey includes
cicadas, katydids, scorpions, centipedes, beetles, grasshoppers, moths.
Big brown (Eptesicus
fuscus)
Daytime roosts are in dark places, usually in buildings or trees. Night
roosts include buildings. Females form maternity colonies, while males
remain solitary. Females return to the same summer roost in March or
April. Pups born in spring or early summer. Feeds on insects in meadows,
over water, among trees, and in the urban environment.
Long-eared myotis (Myotis
evotis)
Roosts both singly and in maternity colonies in abandoned buildings,
hollow trees, niches under bark, caves, mines, cliff crevices. Forages around
treetops and over water in forested areas. Pups born June-July.
Fringed myotis (Myotis
thysanodes)
Females roost in colonies, males usually roost alone. Roost in caves, mines,
rock crevices, buildings. Forages along streams and in forested areas. Pups
born June-July.
Long-legged (Myotis
volans)
In the summer, roosts in colonies in buildings, crack, crevices, and in loose
and peeling tree bark. In the winter, roosts in caves and mines. Forages for
insects over water, in forests, over open habitat and near cliffs. Pups born
spring/summer.
Hoary (Lasiurus cinereus) A solitary bat that roosts in the foliage of trees, usually 7-20 feet above the
ground and leafed above but open below. Roost trees are usually at the
edge of a clearing. Markings blend well with tree bark. Regularly makes a
chattering sound during flight audible to human ears. Forages at treetop
levels in open areas, over streams, and may also be attracted to insects at
outdoor lights. Pups born May-July.
Silver-haired
(Lasionycteris
noctivagans)
Roosts singly or in small groups in wooded areas. Prefers hollows, cracks
and crevices of trees. Sometimes found roosting in old woodpecker holes
and beneath rocks. Roosts usually between 3 and 16 feet above the ground.
Forages over ponds and streams, and above treetop level in woodland. Has
been observed to fly the same pattern each night. Migratory; during
migration they can be found in open sheds, garages and outbuildings,
lumber piles. On hibernation grounds they hibernate in trees, buildings,
rock crevices, caves. Pups born June-July.
Williams et al. 2002 Beginner’s Guide to Bats
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 63
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Table 3 Non-listed Native Plants of Concern in Foothills Park
Plant Name Bloom Period Comments about
occurrences in the
Park
Fire Plan
Treatments of
concern
Rayless arnica
Arnica discoidea
May-July Open slopes and edges
of chaparral; Los
Trancos Trail
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
Crimson columbine
Aquilegia formosa
A. eximia
May-August Mixed evergreen forest,
brush covered slopes.
Usually in damp, shady
places along trails; Los
Trancos Trail
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Maidenhair fern
Adiantum jordanii
na Moist, shaded slopes in
woodland. Not
uncommon, but can be
severely impacted.
Fern Loop, Steep
Hollow Trails
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Kellogg’s or lax snapdragon
Antirrhinum kelloggii
March-May Disturbed areas,
especially burns, and
chaparral
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
Single-leaf onion
Allium unifolium
April-June Moist clay or
serpentine, grassy
streambanks
none
Indian paintbrush
Castilleja affinis
March-May Open slopes, borders of
chaparral and wooded
areas. Woodrat Trail.
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Wooly Indian paintbrush
Castilleja foliolosa
March-June Edges of chaparral, on
dry rocky slopes
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
Venus thistle
Cirsium occidentale
venustum
April-July Disturbed places in
grassland and woodland
F.E.1, F.E.2, F.E.3,
F.E.4, F.E.6,
F.D.1, F.D.2,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.8 F.D.9, F.I.1,
F.I.2, F.I.3, F.I.4,
F.I.6, F.C.1, F.C.2,
F.C.4, F.C.5,
F.C.6, F.F.1, F.F.2,
F.F.3, F.F.4
California larkspur
Delphinium californicum
May-June Grows in thickets and
chaparral. Known along
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 64
TRA Environmental Sciences 1/8/2009
Table 3 Non-listed Native Plants of Concern in Foothills Park
Plant Name Bloom Period Comments about
occurrences in the
Park
Fire Plan
Treatments of
concern
Los Trancos Trail F.D.9, F.C.3,
F.C.4, F.C.6
Hooker’s fairy bells
Disporum hookeri
March-May Shaded places in mixed
forest and brush. Steep
Hollow and Los
Trancos Trails
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Red delphinium
Delphinium nudicaule
March-June Mixed evergreen forest,
dense riparian
woodland. Los Trancos
Trail
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Bush poppy
Dendromecon rigida
April-August (highly
variable)
Chaparral. Trapper’s
Trail
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
California fuschia
Epilobium canum
August-October Rocky soil in chaparral F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
Checker lily
Fritillaria affinis
February-May Wooded slopes, oak
scrub, grasslands
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Rosilla or sneezeweed
Helenium puberulum
June-September Creek beds and marshy
meadows along streams
and lakes. Panorama
Trail
F.E.2, F.E.5
Hill lotus
Lotus humistratus
March-June Grassland, chaparral F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
California lotus
Lotus wrangelianus
March-June Chaparral, disturbed
areas
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
Coffee fern
Pellaea andromedifolia
na Dry, open or shaded
habitats often in
chaparral. Los Trancos
Trail
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
California polypody
Polypodium californicum
na Shaded canyons and
streambanks
F.E.1, F.E.2
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 65
TRA Environmental Sciences 1/8/2009
Table 3 Non-listed Native Plants of Concern in Foothills Park
Plant Name Bloom Period Comments about
occurrences in the
Park
Fire Plan
Treatments of
concern
Bird’s-foot fern
Pellaea mucronata
na Dry, rocky outcrops.
Los Trancos Trail
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
Gold-back fern
Pityrogramma triangularis
na Shaded slopes in oak-
madrone woodland,
brushy slopes, moist
banks
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Chaparral currant
Ribes malvaceum
October-March Shaded ravines and
chaparral slopes. Bobcat
Point
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
California tea
Rupertia physodes
April-June Oak-madrone woods,
shaded chaparral.
Panorama Trail.
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Victor’s gooseberry
(Ribes victoris)
March-April Canyon forests and
chaparral. Costanoan
Trail.
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D.9, F.C.3,
F.C.4, F.C.6
Yerba buena
Satureja douglasii
April-September Shade in woodland F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Fat false solomon’s seal
Smilacina racemosa
March-May Shade and rich soil in
mixed evergreen forest
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Slim false solomon’s seal
Smilacina stellata
April-June Wooded slopes in
partial shade
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Dannie’s skullcap
Scutellaria tuberosa
March-July Oak-madrone woods,
borders of shrubby
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 66
TRA Environmental Sciences 1/8/2009
Table 3 Non-listed Native Plants of Concern in Foothills Park
Plant Name Bloom Period Comments about
occurrences in the
Park
Fire Plan
Treatments of
concern
vegetation F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Hartweg’s taushcia
Tauschia hartwegii
March-May Occasional on wooded
slopes.
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Kellogg’s tauschia
Tauschia kelloggii
April-June Grassland, edges of
chaparral
F.C.1, F.C.2,
F.C.3, F.F.1, F.F.2,
F.F.3. F.F.4, F.C.6
Pacific starflower
Trientalis latifolia
April-July Shaded slopes, moist
woods
F.E.1, F.E.2, F.E.3,
F.E.6, F.D.1,
F.D.3, F.D.4,
F.D.5, F.D.6,
F.D.9, F.I.1, F.I.2,
F.I.3, F.I.4, F.I.6,
F.C.6
Western verbena
Verbena lasiostachys
May-September Dry ground of disturbed
areas, creek bottoms,
roadsides, edges of
brushy vegetation
F.E.2, F.E.5
Source: Foothills Park Trails Management Plan 2001; TRA 2008; Munz and Keck 1968.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 67
TRA Environmental Sciences 1/8/2009
Table 4. Fire Plan Treatments, Habitats Affected, and Protective Measures
Designation Project Description Acreage Treatment
Method
Habitat(s)
Affected1 Protection
Measure ID2
Foothills Park Treatment Locations
Evacuation Routes
F.E1 Page Mill Road
Within PA City
from
Arastradero to
southern Pony
Tracks
9.54
acres
mowing,
grazing, hand
labor
Grassland
Chaparral
Woodland
1, 2, 3, 4, 7,
9, 10
F.E2
Evacuation
Route - Park
Road
Entrance to
Maintenance
Yard Las
Trampas Valley
5.96
acres
mowing,
grazing, hand
labor
Woodland
Irrigated
Meadow
1, 2, 3, 4, 5,
7, 9, 10
F.E3
Evacuation
Route - Park
North west
Interpretive
Center to
Hewlett property
0.57
acres
mowing,
grazing, hand
labor
Grassland
Woodland
1, 2, 3, 4, 7,
9, 10
F.E4
Evacuation
Route - Park
North east
Boronda Lake to
Alexis Drive
1.21
acres
mowing,
grazing, hand
labor
Grassland
1, 9
F.E5 Secondary Evac
Route
Towle
Campground to
Las Trampas
Valley
0.97
acres
mowing,
grazing, hand
labor
Riparian
(coyote brush)
1, 2, 3, 4, 5,
9
F.E6 Los Trancos
Southwest
corner of
Arastradero Park
6.07
acres
Hand labor
Woodland
Riparian
(Willow)
(*western
leatherwood)
1, 2, 3, 4, 7,
10
Firefighter Safety Zone
F.F1 Firefighter
Safety Zone 1
Trappers Ridge
& Los Trancos
Trail
0.72 acre mow, graze
Grassland
Chaparral
Coastal Scrub
1, 2, 3, 9
F.F2 Firefighter
Safety Zone 2
Trappers Ridge
& Madron Fire
Road
0.72 acre mow, graze
Grassland
Chaparral
Coastal Scrub
1, 2, 3, 9
F.F3 Firefighter
Safety Zone 3
Trappers Ridge
high point
0.72 acre mow, graze
Grassland
Chaparral
Coastal Scrub
1, 2, 3, 9
F.F4
Firefighter
Safety Zone 4
Trapper Ridge
south end
0.72 acre mow, graze
Grassland
Chaparral
Coastal Scrub
1, 2, 3, 9
Defensible Space
F.D.1 Defensible
Space Entry Gate 0.72 acre hand labor
Grassland
Woodland
1, 2, 3,`4, 7,
9, 10
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 68
TRA Environmental Sciences 1/8/2009
Table 4. Fire Plan Treatments, Habitats Affected, and Protective Measures
Designation Project Description Acreage Treatment
Method
Habitat(s)
Affected1 Protection
Measure ID2
Foothills Park Treatment Locations
F.D.2 Defensible
Space Station 8 0.72 acre hand labor
Grassland 1
F.D.3 Defensible
Space
Restrooms at
Orchard Glen < ½ acre hand labor
Woodland 1, 2, 3, 4, 7,
9, 10
F.D.4 Defensible
Space
Interpretive
Center 0.11 acre hand labor
Woodland
Irrigated
Meadow
1, 3, 4, 7, 9,
10
F.D.5 Defensible
Space
Maintenance
Complex 0.72 acre hand labor
Woodland 1, 3, 4, 7, 10
F.D.6 Defensible
Space
Boronda Pump
Station at
Campground
0.72 acre hand labor
Woodland 1, 2, 3, 4, 7,
9, 10
F.D.7 Defensible
Space
Dahl Water
Tank
< 1/2
acre
hand labor,
grazing
Chaparral 1, 2, 3, 9
F.D.8 Defensible
Space Boronda Tank < 1/2
acre
hand labor,
grazing
Grassland
1
F.D.9 Defensible
Space Park Tank < 1/2
acre
hand labor,
grazing
Grassland
Chaparral
Woodland
1, 2, 3, 4, 7,
9, 10
Ignition Prevention
F.I.1
Ignition
Prevention
Shady Cove
Picnic Area < 1/4 ac hand labor
Woodland 1, 3, 4, 7, 10
F.I.2
Ignition
Prevention
Encinal Picnic
Area < 1/4 ac hand labor
Woodland 1, 3, 4, 7, 10
F.I.3
Ignition
Prevention
Pine Gulch
Picnic Area < 1/4 ac hand labor
Woodland 1, 3, 4, 7, 10
F.I.4
Ignition
Prevention Orchard Glen < 1/4 ac hand labor
Woodland 1, 3, 4, 7, 10
F.I.5
Ignition
Prevention
Oak Grove
Group Picnic
Area < 1/4 ac hand labor
Woodland 1, 3, 4, 7, 10
F.I.6
Ignition
Prevention Towle Camp < 1/4 ac hand labor
Woodland 1, 3, 4, 7, 10
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 69
TRA Environmental Sciences 1/8/2009
Table 4. Fire Plan Treatments, Habitats Affected, and Protective Measures
Designation Project Description Acreage Treatment
Method
Habitat(s)
Affected1 Protection
Measure ID2
Foothills Park Treatment Locations
Containment
F.C1 Containment Trappers Trail 72.51
acres
mowing,
grazing
Grassland
Coastal Scrub
1, 2, 3, 9
F.C2 Containment
Pony Tracks
south of
Trappers Ridge
1.37
acres
mow annually
10-ft on either
size of road,
use a brush
hog (or
grazing
animals) to
mow areas to
the break in
slope both
under wooded
canopy and in
grasslands
with cover of
coyote brush
greater than
30%
Grassland
Coastal Scrub
1, 2, 3, 9
F.C3 Containment
Pony Tracks
north of
Trappers Ridge 1.13
acres
mowing,
grazing
Chaparral 1, 3, 9
F.C4 Containment Bobcat point 5.28
acres
graze with
goats
Grassland
Chaparral
1, 2, 3
F.C5 Containment North of entry
Gate
3.47
acres
graze with
goats
Grassland 1
F.C6 Containment "Valley View
Fire Trail"
3.35
acres mowing
Chaparral
Woodland
1, 2, 3, 4
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 70
TRA Environmental Sciences 1/8/2009
Table 4. Fire Plan Treatments, Habitats Affected, and Protective Measures
Designation Project Description Acreage Treatment
Method Habitat Measure
Pearson Arastradero Treatment Locations
Evacuation Route
A.E1 Evacuation
Route
Arastradero
Road
2.32 acres
mowing,
grazing, hand
labor
Grassland
Riparian
(Willow)
Eucalyptus Trees
1, 8
Defensible Space
A.D1 Defensible
Space
Gateway
Building 0.72 acre hand labor,
mowing
Grassland 1
A.D2 Defensible
Space Restrooms 0.72 acre hand labor,
mowing
Grassland 1
A.D3 Defensible
Space
Corte Madera
Pump Station 0.72 acre hand labor,
mowing
Woodland 1, 2, 3, 4, 7,
10
A.D4 Defensible
Space Water Tank 0.72 acre hand labor,
mowing
Woodland 1, 2, 3, 4, 7,
10
Containment
A.C1 Containment
Property
boundary
adjacent to
Liddicoat
5.39 acres grazing,
mowing
Grassland 1
A.C2 Containment
Property
boundary
adjacent to
Stanford and
Portola
Pastures
grazing,
mowing
Grassland 1
A.C3 Containment
Within
Redtail Loop
Trail, to
entire eastern
boundary of
Preserve
48.72 acres grazing
Grassland 1, 8
A.C4 Containment
Property
boundary
adjacent to
Paso del
Robles
7.71 acres grazing
Grassland
(serpentine)
1, 2
A.C5 Containment
Property
boundary
Laurel Glen -
north
11.22 acres grazing
Woodland 1, 2, 3, 4,
10
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 71
TRA Environmental Sciences 1/8/2009
Table 4. Fire Plan Treatments, Habitats Affected, and Protective Measures
Designation Project Description Acreage Treatment
Method Habitat Measure
Pearson Arastradero Treatment Locations
A.C6 Containment
Property
boundary
Laurel Glen -
south
4.05 acres grazing
Grassland
Woodland
1, 2, 3, 4
A.C7 Containment
Property
boundary
west of
Meadow
Lark Trail
9.71 acres grazing,
mowing
Woodland
Coastal Scrub
(serpentine)
1, 2, 3, 4
A.C8 Containment
Property
boundary
adjacent to
1791
Arastradero
Rd.
8.08 acres
grazing
(mowing is not
possible)
Woodland 1, 2, 3, 4
A.C9 Containment
Property
boundary
adjacent to
John
Marthens
0.79
acres
mowing
Grassland
Woodland
Riparian
Coastal Scrub
1, 2, 3, 4, 5,
7, 10
A.C10 Containment
Arastradero
Creek to
Arastradero
Road
14.08
acres
mowing, hand
labor near
riparian zone
Grassland
Woodland
Riparian
1, 2, 3, 4, 5,
7, 8, 10
A.C11 Containment
Meadow
Lark to Juan
Bautista Trail
4.08
acres
mowing
Grassland 1, 2
A.C12 Containment Meadow
Lark
0.72
acres
mowing
Grassland 1
A.C13 Containment Bowl Loop 0.64
acres
mowing
Grassland 1
A.C14 Containment
Arastradero
to extended
split RX1 and
RX2
0.84
acres
mowing
Grassland 1, 8
A.C15 Containment Acorn Trail
0.56
acres
mowing
Grassland 1, 8
Prescribed Burn – Containment
A.Rx1 Containment
Juan Bautista
Prescribe fire
north
18.25 acres Rx fire, grazing
Grassland 1, 2, 8
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 72
TRA Environmental Sciences 1/8/2009
Table 4. Fire Plan Treatments, Habitats Affected, and Protective Measures
Designation Project Description Acreage Treatment
Method Habitat Measure
Pearson Arastradero Treatment Locations
A.Rx2 Containment
Acorn Trail
Prescribed
fire south
24.45 acres Rx fire, grazing
Grassland
Woodland
1, 2, 3, 4,
8
Off-site Treatment Locations
PA.1 Page Mill
Road
From Foothill
Park South to
Skyline Blvd.
16.50
acres
mowing,
grazing, hand
labor
Chaparral
Woodland
Grassland
1, 2, 3, 4, 7,
10
PA.2 Arastradero
Road
From Page
Mill to
Arastradero
Pk, and from
Arastradero
Pk to Los
Trancos
0.21
acres
mowing,
grazing, hand
labor
Grassland
Woodland
1, 3, 4, 7,
10
PA.3
(Same as
FE.6)
Los Trancos
Within PA
City roughly
from Buck
Meadows Dr.
to Meadow
Creek Ct.
6.07
acres hand labor
Riparian
(Willow)
Woodland
(*western
leatherwood)
1, 2, 3, 4, 7,
10
PA.4 Skyline
Blvd. Skyline Blvd. 10.89 acres
mowing,
grazing, hand
labor
Grassland
Woodland
1, 2, 3, 4, 7,
10
1See Table 5 for a list of special-status species by habitat type.
2 Recommended Measures to Avoid Significant Biological Impacts under CEQA
1. Vegetation removal in any vegetation type from February 15 to August 31 requires a survey for nesting birds by
a qualified biologist3 or by park staff trained to do so by a qualified biologist and avoiding removal of nests in active
use. If raptor nests are detected, a buffer area will need to be established around the nest in consultation with the
California Department of Fish and Game. The buffer may be 250 feet.
2. Vegetation removal in areas of serpentine soil, oak woodland, chaparral, coastal scrub and riparian forest habitats
requires a survey for rare plant species by a qualified biologist/ botanist prior to vegetation removal. Known rare
plant locations should be treated in a way that benefits the rare species. This may include limiting the area of
treatment in order to provide a buffer around the plant(s), or may include selectively trimming competitive
vegetation adjacent to the plant(s). Some species may benefit from disturbance; the specific actions to be taken
should be determined in consultation with a botanist. The plant survey needs to occur during the bloom period.
After surveys in the same locations over three separate years, subsequent surveys are not necessary in that area
unless a newly listed plant species could occur in the habitat. This should be determined by consulting the
California Department of Fish and Game.
3. Vegetation removal, including dead and downed debris, requires a survey for presence of San Francisco dusky-
footed woodrat by a qualified biologist or by park staff trained to identify woodrat houses by a qualified biologist .
If woodrat houses are found, disturbance should be avoided and a minimum five-foot buffer should be provided
around the house. If, for public safety reasons, it is necessary to move the house, the process must be coordinated
with the California Department of Fish and Game. It is recommended that workers receive instruction regarding
woodrat houses prior to their start of work.
3 A “qualified biologist” is a person with demonstrated ability to identify special-status plant and/or animal species
in the San Francisco Bay Area.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 73
TRA Environmental Sciences 1/8/2009
4. Prior to the removal of any tree that is 12 inches or more in diameter breast height, a survey for perennial bat
roosts and, during the breeding season from February 15 to August 31, raptor nests shall be conducted by a qualified
biologist or park staff trained by a qualified biologist to identify these resources is required. If present, removal
cannot continue without CDFG guidance.
5. Discing within 500 feet of a lake, pond or creek, requires a biological survey to determine impacts to California
red-legged frog, California tiger salamander, San Francisco garter snake and Western pond turtle and whether
permits are required from the USFWS/CDFG.
6. Discing in grassland requires a pre-construction survey for American badger, California red-legged frog, and
burrowing owl by a qualified biologist.
7. Trimming of coast live oaks shall follow the City’s Tree Ordinance (Title 8). Coast live oak or Valley oaks that
are 11.5 inches in diameter or more measured at 54 inches above grade may not be removed without a permit, and
may not be pruned such that more than 25 percent of the crown is removed or the tree is left unbalanced.
8. Avoid wetlands mapped in Pearson-Arastradero Preserve when weed-whipping or mowing. Modify the Fire
Management Plan Best Management Practice that requires that a grazing plan be prepared to include protection of
drainages and wetlands from the impacts of grazing animals.
9. For treatments in Foothills Park or on Page Mill Road along the Park border, a pre-work survey for stands of
locally important plants (see Table 3 in Appendix A) should be conducted, and the plants avoided as long as it does
not impair public safety. Field crews should be educated about the sensitivity of these plant species.
10. In addition to BMP-5, it is recommended that measures be taken to clean equipment, tires, and shoes to prevent
the spread of Sudden Oak Death, and that any materials infected with the disease be disposed of in accordance with
State or County Agricultural Commission guidelines. To reduce the possibility of spreading the disease, it is
recommended that work not be done in wet or muddy conditions, and that infested areas be avoided to the extent
feasible. Additional guidelines are available from the County Agricultural Commissioner.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 74
TRA Environmental Sciences 1/8/2009
Table 5. Special-status Species by Habitat Type and Treatment Location, with Protection
Measures
Species by Habitat Type Treatment
Locations
Protection Measures
Chaparral
San Francisco dusky-footed
woodrat
Ringtail
Loggerhead shrike
Arcuate bush mallow
(serpentine)
Kings Mountain manzanita
Marin western flax
(serpentine)
San Francisco campion
San Mateo thornmint
Santa Cruz Mts manzanita
Nesting birds
Foothills Park
F.E.1, F.F.1, F.F.2,
F.F.3, F.F.4, F.D.7,
F.D. 9, F.C. 3, F.C.
4, F.C. 6
Pearson-
Arastradero
Preserve
P.A. 1
1. Vegetation removal from February
15 to August 31 requires a survey for
nesting birds and avoiding removal of
nests in active use.
2. Vegetation removal in areas of
serpentine soil requires a survey for
rare plant species prior to vegetation
removal. Known rare plant locations
should be treated in a way that benefits
the rare species. The plant survey
needs to occur during the bloom
period. After surveys in the same
locations over three separate years,
subsequent surveys are not necessary
in that area unless there are newly
listed plant species that could occur in
the habitat.
3. Vegetation removal, including dead
and downed debris, requires a survey
for presence of San Francisco dusky-
footed woodrat and coordination with
CDFG as necessary.
Coastal Scrub
San Francisco dusky-footed
woodrat
Bats (including pallid bat and
red bat)
Crystal Springs lessingia
(serpentine)
Fragrant fritillary (serpentine)
Franciscan onion (serpentine)
Kings Mountain manzanita
San Francisco campion
Wooly-headed lessingia
Nesting birds
Foothills Park
F.F. 1, F.F. 2, F.F.
3, F.F. 4, F.C. 1,
F.C. 2
Pearson-
Arastradero
Preserve
A.C. 7, A.C. 9
1. Vegetation removal from February
15 to August 31 requires a survey for
nesting birds and avoiding removal of
nests in active use.
2. Vegetation removal in areas of
serpentine soil requires a survey for
rare plant species prior to vegetation
removal. Known rare plant locations
should be treated in a way that benefits
the rare species. The plant survey
needs to occur during the bloom
period. After surveys in the same
locations over three separate years,
subsequent surveys are not necessary
in that area unless there are newly
listed plant species that could occur in
the habitat.
3. Vegetation removal, including dead
and downed debris, requires a survey
for presence of San Francisco dusky-
footed woodrat and coordination with
CDFG as necessary.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 75
TRA Environmental Sciences 1/8/2009
Table 5. Special-status Species by Habitat Type and Treatment Location, with Protection
Measures
Species by Habitat Type Treatment
Locations
Protection Measures
Grassland
American badger
California red-legged frog
(burrows used during part of
life cycle)
California tiger salamander
(burrows used)
Western pond turtle (burrows
used)
White-tailed kite (forage, not
nesting)
Northern harrier (forage, not
nesting)
Golden eagle (forage, not
nesting)
Burrowing owl
Long-eared owl (forage, not
nesting)
Loggerhead shrike
Ground nesting birds (e.g.
Meadowlark, killdeer)
Saltmarsh common
yellowthroat (forage, not
nesting)
Fountain thistle (serpentine)
Crystal Springs lessingia
(serpentine)
Fragrant fritillary (serpentine)
Franciscan onion (serpentine)
Marin western flax
(serpentine)
San Francisco campion
San Mateo thornmint
Wooly-headed lessingia
(serpentine)
Foothills Park
F.E. 1, F.E. 3, F.E.
4, F.F. 1, F.F. 2,
F.F. 3, F.F. 4, F.D.
1, F.D. 2, F.D. 8,
F.D. 9, F.C. 1, F.C.
2, F.C. 4, F.C. 5
Pearson-
Arastradero
Preserve
A.E. 1, A.D. 1, A.D.
2, A.C. 1, A.C. 2,
A.C. 3, A.C. 4, A.C.
6, A.C. 9, A.C. 10,
A.C. 11, A.C. 13,
A.C. 14, A.C.15,
ARx1, ARx2, P.A. 1,
P.A. 2, P.A. 4
1. Vegetation removal from February
15 to August 31 requires a survey for
nesting birds and avoiding removal of
nests in active use.
2. Vegetation removal in areas of
serpentine soil requires a survey for
rare plant species prior to vegetation
removal. Known rare plant locations
should be treated in a way that benefits
the rare species. The plant survey
needs to occur during the bloom
period. After surveys in the same
locations over three separate years,
subsequent surveys are not necessary
in that area unless there are newly
listed plant species that could occur in
the habitat.
4. Discing within 500 feet of a lake,
pond or creek, requires a biological
survey to determine impacts to
California red-legged frog, California
tiger salamander, San Francisco garter
snake and Western pond turtle and
whether permits are required from the
USFWS/CDFG.
5. Discing in grassland requires a pre-
construction survey for American
badger, California red-legged frog, and
burrowing owl by a qualified biologist.
Woodland
San Francisco dusky-footed
woodrat
Bats (including pallid bat and
red bat)
American badger
Ringtail
California red-legged frog
(aquatic and upland)
Foothills Park
F.E. 1, F.E 2, F.E.
3, F.E. 6, F.D.
1,F.D. 3, F.D. 4,
F.D. 5, F.D. 6, F.D.
9, F.I. 1, F.I. 2, F.I.
3, F.I. 4, F.I. 6,
1. Vegetation removal from February
15 to August 31 requires a survey for
nesting birds and avoiding removal of
nests in active use.
2. Vegetation removal in areas of
serpentine soil (in any habitat type), or
in woodland, chaparral and riparian
forest habitats requires a survey for
rare plant species prior to vegetation
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 76
TRA Environmental Sciences 1/8/2009
Table 5. Special-status Species by Habitat Type and Treatment Location, with Protection
Measures
Species by Habitat Type Treatment
Locations
Protection Measures
California tiger salamander
White-tailed kite (nesting)
Golden eagle (nesting)
Loggerhead shrike
Long-eared owl (nesting)
Yellow warbler (nesting)
Crystal Springs lessingia
(serpentine)
Dudley’s lousewort
Franciscan onion
Kings Mountain manzanita
Santa Clara red ribbons
San Francisco collinsia
Santa Cruz Manzanita
Western leatherwood
Wooly-headed lessingia
Nesting birds
F.C. 6
Pearson-
Arastradero
Preserve
A.D. 3, A.D. 4, A.C.
5, A.C. 6, A.C. 7,
A.C. 8, A.C. 9, A.C.
10
ARx2, P.A. 1, P.A.
2, P.A. 3, P.A. 4
removal. Known rare plant locations
should be treated in a way that benefits
the rare species. The plant survey
needs to occur during the bloom
period. After surveys in the same
locations over three separate years,
subsequent surveys are not necessary
in that area unless there are newly
listed plant species that could occur in
the habitat.
3. Vegetation removal, including dead
and downed debris, requires a survey
for presence of San Francisco dusky-
footed woodrat and coordination with
CDFG if it is necessary to move the
woodrat house.
4. Prior to the removal of any tree that
is 12 inches or more in diameter breast
height, a survey for perennial bat roosts
and raptor nests by a qualified biologist
is required. If present, removal cannot
continue without CDFG guidance.
Riparian Forest/Aquatic
San Francisco dusky-footed
woodrat
Ringtail
Bats
Western pond turtle
California red-legged frog
California tiger salamander
Rainbow trout/steelhead
Saltmarsh Common
yellowthroat
San Francisco garter snake
Northern harrier
White-tailed kite
Arcuate bush mallow
(serpentine)
Western leatherwood
Nesting birds
Foothills Park
F.E. 4, F.E. 5, F.E.
6
Pearson-
Arastradero
Preserve
A.E. 1, A.C. 9, A.C.
10, ARx2, P.A. 3
1. Vegetation removal from February
15 to August 31 requires a survey for
nesting birds and avoiding removal of
nests in active use.
2. Vegetation removal in areas of
serpentine soil (in any habitat type), or
in woodland, chaparral and riparian
forest habitats requires a survey for
rare plant species prior to vegetation
removal. Known rare plant locations
should be treated in a way that benefits
the rare species. The plant survey
needs to occur during the bloom
period. After surveys in the same
locations over three separate years,
subsequent surveys are not necessary
in that area unless there are newly
listed plant species that could occur in
the habitat.
3. Vegetation removal, including dead
and downed debris, requires a survey
for presence of San Francisco dusky-
footed woodrat and coordination with
CDFG if it is necessary to move the
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 77
TRA Environmental Sciences 1/8/2009
Table 5. Special-status Species by Habitat Type and Treatment Location, with Protection
Measures
Species by Habitat Type Treatment
Locations
Protection Measures
woodrat house.
4. Prior to the removal of any tree that
is 12 inches or more in diameter breast
height, a survey for perennial bat roosts
and, during the breeding season from
February 15 to August 31, raptor nests
shall be conducted by a qualified
biologist is required. If present,
removal cannot continue without
CDFG guidance.
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 78
TRA Environmental Sciences 1/8/2009
Table 6. Change in Area Impacted under the Fire Management Plan
Current
Treatment
Approximate
Acreage
Treatment
Location
Fireplan
Treatment
Acreage Change in
treatment
Habitat
Type
Foothill Park
Disking
annually;
mowing 5 ft on
both sides of
road; 10ft
annually
3.18 acres F.E. 1
Mowing,
grazing, hand
labor for 30 ft
on both sides;
60 ft total
9.54
acres
6.36 acres
Grassland
Chaparral
Woodland
Mow 7 ft on
both sides of
the road; total
14 ft
2.32 acres F.E. 2
Mowing,
grazing, hand
labor for 30 ft
on both sides;
60 ft total
5.96
acres
3.64 acres
Woodland
Irrigated
Meadow
Mow 7 ft on
both sides of
the road; total
14 ft
0.41 acres
F.E. 3
Mowing,
grazing, hand
labor for 30 ft
on both sides;
60 ft total
.57 acres .16 acres Grassland
Woodland
Mow 7 ft on
both sides of
the road; total
14 ft; Disking
annually
0.84 acres F.E. 4
Mowing,
grazing, hand
labor for 30 ft
on both sides;
60 ft total
1.20
acres .36 acres Grassland
Aquatic
Mow 7 ft on
both sides of
the road; total
14 ft; mowing
of valley for
yellow star
thistle control
0.91 acres F.E. 5
Mowing,
grazing, hand
labor for 15 ft
on both sides;
30 ft total
0.97
acres 0.06 acre
Riparian
(coyote
brush)
No work -- F.E.6
Mowing,
hand labor
near riparian
zone; 30 ft on
both sides; 60
ft total
6.07
acres
6.07 acres
Woodland
Riparian
(Willow)
(*western
leatherwood)
No work -- F.D.1 Hand labor 0.72 acre 0.72 acre Grassland
Woodland
100 ft
clearance
around Fire
Station 8
0.72 acre F.D. 2
Hand labor;
100 ft
clearance
0.72 acre 0 acre Grassland
20 foot
clearance 0.01 acre F.D. 3
Hand labor;
100 ft
clearance
0.72 acre 0.71 acre Woodland
No work -- F.D. 4 Hand labor 0.11 acre 0.11 acre
Woodland
Irrigated
Meadow
20 foot
clearance 0.01 acre F.D. 5
Hand labor;
100 ft
clearance
0.72 acre 0.71 acre Woodland
No work -- F.D. 6 hand labor 0.72 acre 0.72 acre Woodland
No work -- F.D. 7 hand labor,
grazing 0.72 acre 0.72 acre
Chaparral
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 79
TRA Environmental Sciences 1/8/2009
Table 6. Change in Area Impacted under the Fire Management Plan
Current
Treatment
Approximate
Acreage
Treatment
Location
Fireplan
Treatment
Acreage Change in
treatment
Habitat
Type
No work -- F.D. 8 hand labor,
grazing 0.72 acre 0.72 acre Grassland
No work -- F.D. 9 hand labor,
grazing 0.72 acre 0.72 acre
Grassland
Chaparral
Woodland
300 foot
firebreak on
Trappers
Ridge;
mowing
annually;
brush mowing
every 2-4
years
72.51 acres F.C. 1
Mowing,
grazing, 10-
30 ft along
Trappers
Ridge
annually, 300
ft every 3
years
72.51
acres 0 acre
Grassland
Coastal
Scrub
mowing
annually;
brush mowing
every 2-4
years
1.37 acres F.C. 2
Mow
annually 10-
ft on either
size of road,
use a brush
hog (or
grazing
animals) to
mow areas to
the break in
slope both
under
wooded
canopy and in
grasslands
with cover of
coyote brush
greater than
30%
1.37
acres 0 acre
Grassland
Coastal
Scrub
mowing
annually;
brush mowing
every 2-4
years
1.13 acres F.C. 3
Mowing,
grazing for
10 ft on both
sides of the
trial, 20 ft
total
1.13
acres 0 acre Chaparral
No work --- F.C. 4 graze with
goats
5.28
acres 5.28 acres Grassland
Chaparral
Disking of half
of the route 1.74 acres F.C. 5 Graze with
goats
3.47
acres 1.73 acres Grassland
Mowing
annually, 2-4
year brush and
tree trimming
3.35 acres F.C. 6
Mowing for
10 ft on both
sides of the
trail, 20 ft
total
3.35
acres 0 acre Chaparral
Woodland
Mowing
annually 0.72 acre F.F. 1 mow, graze 0.72 acre 0 acre
Grassland
Chaparral
Coastal
Scrub
Mowing
annually 0.72 acre F.F. 2 mow, graze 0.72 acre 0 acre Grassland
Chaparral
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 80
TRA Environmental Sciences 1/8/2009
Table 6. Change in Area Impacted under the Fire Management Plan
Current
Treatment
Approximate
Acreage
Treatment
Location
Fireplan
Treatment
Acreage Change in
treatment
Habitat
Type
Coastal
Scrub
Mowing
annually 0.72 acre F.F. 3 mow, graze 0.72 acre 0 acre
Grassland
Chaparral
Coastal
Scrub
Mowing
annually 0.72 acre F.F. 4 mow, graze 0.72 acre 0 acre
Grassland
Chaparral
Coastal
Scrub
Weed
whipping
annually
< 1/4 ac F.I. 1 hand labor < 1/4 ac 0 acre Woodland
Weed
whipping
annually
< 1/4 ac F.I. 2 hand labor < 1/4 ac 0 acre Woodland
Weed
whipping
annually
< 1/4 ac F.I. 3 hand labor < 1/4 ac 0 acre Woodland
Weed
whipping
annually
< 1/4 ac F.I. 4 hand labor < 1/4 ac 0 acre Woodland
Weed
whipping
annually
< 1/4 ac F.I. 5 hand labor < 1/4 ac 0 acre
Irrigated
Meadow
Weed
whipping
annually
< 1/4 ac F.I. 6 hand labor < 1/4 ac 0 acre Woodland
Pearson-Arastradeo Preserve
No work -- A.C. 1 grazing,
mowing
5.39
acres 5.39 acres Grassland
Disking
annually 2.47 acres A.C. 2
Grazing,
mowing for
10 ft on both
sides of the
trail, 20 ft
total
2.47
acres 0 acre Grassland
No work -- A.C. 3 grazing 48.72
acres 48.72 acres Grassland
Disking
annually 5.00 acres A.C. 4 Grazing 7.71
acres 2.71 acres Grassland
No work -- A.C. 5 grazing 11.22
acres 11.22 acres Woodland
No work -- A.C. 6 grazing 4.05
acres 4.05 acres Grassland
Woodland
No work -- A.C. 7 grazing,
mowing
9.71
acres 9.71 acres
Woodland
Coastal
Scrub
No work -- A.C. 8
grazing
(mowing is
not possible)
8.08
acres 8.08 acres Woodland
Disking
annually 0.79 acres A.C. 9 Mowing for
10 ft on both
0.79
acres 0 acre Grassland
Woodland
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 81
TRA Environmental Sciences 1/8/2009
Table 6. Change in Area Impacted under the Fire Management Plan
Current
Treatment
Approximate
Acreage
Treatment
Location
Fireplan
Treatment
Acreage Change in
treatment
Habitat
Type
sides of the
trail, 20 ft
total
Riparian
Coastal
Scrub
Mowing
annually, 2-10
year brush
mowing
7.04 acres A.C. 10
Mowing,
hand labor
near riparian
zone; 10 ft on
both sides of
the trail, 20 ft
total
14.08
acres 7.04 acres
Grassland
Woodland
Riparian
Mowing or
weed whipping
annually; 4 ft;
8 ft total
1.63 acres A.C. 11
Mowing for
10 ft on both
sides of the
trail, 20 ft
total
4.08
acres
3.45 acres Grassland
Mowing or
weed whipping
annually; 4 ft;
8 ft total
0.29 acres A.C. 12
Mowing for
10 ft on both
sides of the
trail, 20 ft
total
0.72
acres
0.43 acre Grassland
Mowing or
weed whipping
annually; 4 ft;
8 ft total
0.25 acres A.C. 13
Mowing for
10 ft on both
sides of the
trail, 20 ft
total
0.64
acres
0.39 acre Grassland
Mowing or
weed whipping
annually; 4 ft;
8 ft total
0.34 acres A.C. 14
Mowing for
10 ft on both
sides of the
trail, 20 ft
total
0.84
acres 0.50 acre Grassland
Mowing or
weed whipping
annually; 4 ft;
8 ft total
0.22 acres A.C. 15
Mowing for
10 ft on both
sides of the
trail, 20 ft
total
0.56
acres
0.34 acre Grassland
Mowing
annually; 5 ft,
10 ft total
0.73 acres A.E. 1
Mowing,
grazing, hand
labor for 30 ft
on both sides
of the road;
60 ft total
4.36
acres
3.63 acres
Grassland
Riparian
(Willow)
Eucalyptus
Trees
Mowing; 30
feet clearance .02 acres A.D. 1
Hand labor,
mowing for
100 ft
clearance
0.72 acre 0.70 acre Grassland
Mowing; 30
feet clearance
.02 acres
A.D. 2
Hand labor,
mowing for
100 ft
clearance
0.72 acre 0.70 acre Grassland
No work -- A.D. 3
hand labor,
mowing,
100ft
clearance
0.72 acre 0.72 acre Woodland
No work -- A.D. 4 hand labor, 0.72 acre 0.72 acre Woodland
Foothills Fire Management Plan Biological Impact Assessment-Appendix A Page 82
TRA Environmental Sciences 1/8/2009
Table 6. Change in Area Impacted under the Fire Management Plan
Current
Treatment
Approximate
Acreage
Treatment
Location
Fireplan
Treatment
Acreage Change in
treatment
Habitat
Type
mowing,
100ft
clearance
No work -- A.Rx1 Rx fire,
grazing
18.25
acres 18.25 acres Grassland
No work -- A.Rx2 Rx fire,
grazing
24.45
acres 24.45 acres Grassland
Woodland
No work -- P.A. 1
mowing,
grazing, hand
labor
16.50
acres
16.50
acres
Chaparral
Woodland
Grassland
Mowing
annually; 5 ft,
10 ft total
0.22 acres P.A. 2
mowing,
grazing, hand
labor for 30 ft
both sides of
the road, 60 ft
total
0.22
acres 0 acres
Grassland
Woodland
Mowing
annually; 5 ft,
10 ft total
1.82 acres
P.A. 3
hand labor
for 30 ft both
sides of the
road, 60 ft
total
6.07
acres 4.25 acres
Riparian
(Willow)
Woodland
(*western
leatherwood)
No work -- P.A. 4
mowing,
grazing, hand
labor
10.89
acres
10.89 acres
Grassland
Woodland
Foothills Fire Management
The City of Palo Alto
Planning Department
250 Hamilton Avenue
Palo Alto, CA 94301
240 West Charleston Road
Palo Alto, CA 94306
650-493-3468
March 2, 2009
Attention: ~nndb O.,ekiio City Manager's Office: Clare Campbell, Planning Dept.,
Keilly Morariu, City of Palo Alto.
Re Comments on Mitigated Negative Declaration
Foothills Fire Management Plan
Dear' Kenneth Dueker,
The Mitigated Negative Declaration for the Fire Management Plan is not complete,
correct, or adequate.
Completeness: The plan does not recognize that Foothills and Arastradero Parks are
nature preserves. If saving the parks from fire means losing large areas of the parks
as nature preserves, we have spent a lot of money we don't have and damaged the
nature we were trying to save.
10
That is what this plan does not recognize. For example, clearing 300 feet on each side
of Trappers Trail for a mile and a half means that is not a natural area but rather one
that has been managed. The area is huge and looks unnatural. We lose native plants
that can't tolerate mowing or grazing. The plants that remain are different with some
gone forever, some with no lower branches, some smaller than they normally would be.
The habitat that remains has been changed for birds, animals, and other plants. Also
mechanical equipment has brought in purple star thistle, dittrichia, and plumless thistle
(Carduus acanthoides).These are invasive plants we have found in the park only near
roads.
Correctness: It is clear when you know the area that some of the proposals in the fire
plan really won't work and should not be carried out anyway. For example, Bobcat
Point is not a good place to schedule for containment clearing by grazing and browsing,
The point has a very steep slope with interesting and unusual chaparral plants and
some trees growing on it. We should protect those plants and avoid erosion. In the
park there is no place for mechanical equipment to drive in. Goats would have to walk
the trails to get in. Goats try to eat everything. here is no place nearby to get water for
the goats or to park the goat herder's trailer. That area should be left alone.
Adequacy: It is often not clear in all the writing about the fire reduction proposals why
they are needed, What do they accomplish exactly? Evacuation routes and clearing
Foothills Fire Management '11
around barbecues are understandable, but area treatment of 300-ft-wide areas is not
so simple. Are we saving the park from incoming fires or saving the houses outside the
park from fires starting in the park? For example, the treatment of 72.51 acres on
Trappers Ridge appears to be intended to save the part of the park on the other side
of the Ridge. Do we really need 600 feet of clearing to do that? Is the cost both in
dollars and plant loss worth what we are saving?
Also it would be helpful to know more about how the decisions about the significance of
various factors were made. In other words, why are those important check marks where
they are? We have five references only. They were 1-the planner, 2-the Comp Plan,
3-Title18 Zoning Ordinance, 4-The Foothills Fire Management Plan by Wildland
Resource Management, and 5-Biological Impact Assessment by TRA Environmental
Sciences. Most of those check marks are 1 and 4. The actual work plan appears to
have come from number 4. Additional sources on the fire management need ought to
be found qnd used. Ther~ ought to be more on-the-ground knowledge behind those
decisions.
The following are our specific comments: Many of the impacts are significant rather
than no impact or mitigated impacts. I am using the letters in the Draft EIR (A-Q).
A. Aesthetics (pg21): Sections a, b, and c and the Comp Plan d should be considered
significant impacts. Certainly any area that has been treated in the park is no longer a
natural area but rather a managed area once it has been mowed, grazed, cut, burned,
and cleared. It does not look like a natural area. That is what we look for in a nature
preserve. That is what has been impacted. This applies to the 330 acres in Foothills
an Arastradero Parks that are proposed as fuel management areas (pg 6 of the Draft
Mitigated Declaration). Also as is pointed out in the discussion, the Comp Plan has
designated Arastradero and Page Mill Roads as scenic routes and Skyline is a State
Scenic Highway. They also would be aesthetically hurt by being treated for 30 feet on
both sides of the pavement edge because they are evacuation routes.
C. Air Quality (pg24): I note in the discussion that "Prescribed fires may be executed on
non-burn days as necessitated by logistic concerns". This deserves a check mark
under more than no impact.
D. Biological Resources (pg24): Mitigation methods should protect locally important
plants in all areas, not just those covered in B10-10 for plants on Page Mill Road. For
example, Bobcat Point has a number of locally special plants. Also it is a special area
because it is chaparral growing at an unusually low elevation. And the chaparral
contains an unusual diversity of chaparral plants. There are other areas in the Parks
that have special plants. Can we consider these situations special and class them
under D a?
Also, ordinary plants have an importance that should be recognized. Our wildflowers
and plants like yerba buena, maidenhair fern, sticky monkey, Indian warrior, madrone,
manzanita, ceanothus and many others all deserve protection even though they are
common enough to not be considered special. They are wonderful parts of a nature
preserve and deserve protection. As do the many plants that are not very interesting
but do important jobs as benign occupiers of space. These plants should also be
considered special under D a.
Foothills Fire Management 12
Section D e should be considered potentially significant because this fire management
plan conflicts with the city council established role for Foothills Park and presumably
also Arastradero as a nature preserve or natural area.
E. Cultural Resources (pg 28): Under E a is the nature preserve a local cultural
resource? It is certainly recognized by the City Council. And taking 330 acres for fire
management is a major loss. It is a significant issue.
Under E e: Is the Interpretive Center a historic resource eligible for listing somewhere?
Under E f: Is the fire plan eliminating areas important in the history of the Indian era in
the park?
F. Geology (Pg29) Section F b is checked as potentially significant. This implies that
section F c should be checked because the eroded material would probable wind up as
silt somewhere.
Mitigation Geology F-8 would limit grazing on the Bobcat slope. (Sticking in Geology-9
looks like a typo of stocking). Mitigation Geology-7 would limit use of heavy equipment
on Trappers Trail where there are slopes over 40%.
G. Hazards and Hazardous Materials (Pg 32) H i might be a place to mention the
locked gates on the evacuation route through the Arillaga property. They are being
worked on. A better plan is needed than relying on someone having a key to open the
gates when there is a fire emergency.
H, Hydrogeology and Water Quality (Pg 33) H k "Result in stream bank instability?"
Should be checked Potentially Significant. Removing the Shrubs along the creek side
of the WildHorse Valley Road has been suggested. Doing so would definitely decrease
stream bank stability as the road is close to the creek and the shrubs are supporting
the creek bank.
I. Land Use Planning (Pg 35) Use of land for fire management conflicts with the city
land use plan that designates the area a nature preserve -I b, d.
The plan also does divide existing plant communities-I a.
And the fire management plan would ignore previous efforts to protect native plants
and strengthen biodiversity by removing invasive plants-1 c.
K. Noise (Pg 37) A potential signi'ficant temporary increase in noise from use of
mechanical equipment and removal of tree branches should be considered significant.
One of the things we look for in a nature preserve is freedom from that kind of noise.-
Kd.
L. Population and Housing (Pg38)
The proper question for this category is not asked. We should determine what
decrease in animal and plant population would result from fire treatment activities.
People are concerned and should be concerned about the effect of their activities on
the environment. Treatment will damage the nature preserves. Treatment in areas in
Foothills Park where invasive plants have been removed will damage native plants that
Foothills Fire Management 13
have been encouraged. Treatment tends to bring in new seeds and encourage growth
from invasive plants like yellow and purple starthistle, Italian thistle, and even Dittrichia
graveolens.
M. Public Services (Pg 39) M d The two parks would suffer severe adverse physical
impacts to their the nature preserve function because of the mowing, grazing,
mechanical clearing, cutting of trees and such in 330 acres of Foothills and Arastradero
Parks.
N. Recreation (Pg 39) N a The project would cause SUbstantial physical deterioration of
the two parks. We would have not a natural area in 330 acres of the parks but rather a
managed area of less interest. Note that the discussion of this section says that
enhancing fire safety in the parks would not generate new users.
O. Transportation and Traffic (Pg 40) Q a The plan does add new trips to the parks in
order to carry out the additional mowing, grading, cutting and mechanical control of the
fire load in various areas. Q d The plan will increase traffic hazards by adding new
traffic to old narrow roads, 0 e Inadequate emergency access will continue to exist to
Los Trancos Road until a better evacuation method than a person or person with keys
to unlock the gates to the Arilliga property is agreed upon. The iron Chambers fence is
also an emergency access problem.
P. Utilities and Service Systems(pg 42) P c Additional drainage control will be
necessary in areas where plants are removed that acted to limit erosion. P d The plan
addresses fire fuel management needs but does not address water supply needs for
fire fighting. This is a significant isssue.
Q. Mandatory Findings of Significance (Pg 43) Q a The project does have the potential
to threaten to eliminate a plant or animal community and to reduce the number or
range of an endangered plant or animal community. Dirca (Ieatherwood) has already
been impacted by trail clearing. It is a CNPS rare or endangered species found in
Foothills Park. Q b This project when aI/ its aspects are considered will have a
cumulative effect. There also have been past projects that involved clearing such as
Trappers Trail which add to the park's problems. Q c The loss of trees and other plants
in the interest of fire prevention may affect people by adding to global warming issues.
The loss of habitat for plants and animals means a less rich environment for people as
well.
Conclusions:
1. The problem with this proposal is that it does not respect the purpose of Foothills
Park and also Arastradero. The plaque dated June 18, 1965 from the city council on
the top of Vista Hill says 'It is our purpose in establishing this park to conserve the
natural features and scenic values within its boundaries; to protect and maintain the
ecology of the area; to provide for the use and enjoyment of the resources found here,
consistent with their preservation; to emphasize beauty, simplicity and serenity and to
provide opportunities for the interpretation of natural history and our local heritage."
This means protect what you have rather than manipulate it into something unnatural.
.We should not make the park the default fire mitigation area for the surrounding
Foothills Fire Management 14
houses. We should not artificially change the natural habitat where animals and other
plants are growing. We should not try to force something to grow in an area that it is
not suited for.
The proposed plan presents the idea that the mowing, burning, grazing, cutting tree
limbs and such is going to ecologically improve the park if done carefully. It should
also point out that those same processes can destroy good plants as well. We have
purple star thistle in Foothills Park along Trappers Trail and Pony Track Roads, near
the end of Wildhorse Road, and in the burn area at the end of that road. It is obvious
that it was brought into the park by vehicles. In the same way, we have found Dittrichia
graveolens in the Interpretive Center parking area, along a section of Trappers Trail,
and in the burn area at the end of Wild horse Road. Mowing and goats kill good plants
as well as bad ones. Ceanothus and Bush Poppy don't recover wl1en they are cut
down, for example. In the past the CCC crews removed some Dirca and a lot of
currants forever in their efforts to clear trails. Also we have learned that removing one
kind of invasive plant can lead to erosion or to the establishment of another invasive in
the place that was cleared.
We were told on February 24, 2009 at the Park and Recreation meeting that the state
has just passed a law requiring that all evacuation routes be cleared 30 feet from the
pavement edge. We know that Page Mill, Arastradero, Los Trancos, Skyline, and the
road in Foothills Park are considered evacuation routes to get fire fighters in to areas
where they are needed and to get people out. Are all roads between 280 and Skyline
considered evacuation routes? How is this decision made?
A logical fire mitigation plan would involve conforming to this law once we know more
precisely what it requires, continuing to clear around important buildings like the
Interpretive Center, Entry Hut, and Maintenance Shops, and Arastradero's structures
and taking precautions near barbecues and other places where fire is allowed in the
park. Beyond that, don't clear unless the purpose and need for that additional clearing
is defined and supervised by a fire mitigation expert. Leave Bobcat Point alone.
Reevaluate the need for Trappers Trail Clearing. Property owners should maintain
their own property areas. The day may come where we won't have barbecues in the
park and when building houses in the wildlands is not allowed at all.
Jean Olmsted
240 West Charleston, Palo Alto, CA 94306
650-493-3468
jwo@svpal.org
Acterra Foothill Fire Management Plan Update - Draft Mitigated Negative Declaration
Comments
Authored by Shani Kleinhaus, Ecological Consultant, Acterra Volunteer, Claire Elliott,
Acting Director, Acterra Stewardship, and William Mutch, Chief Steward, Arastradero
Preserve
March 11, 2009
PROJECT DESCRIPTION
7. COMPREHENSIVE PLAN DESIGNATION
Foothill Park may be designated a Public Park, but its spirit and purpose are NOT of an urban
park “whose character is essentially urban” as stated in the Draft Mitigated Negative Declaration,
but as stated in Palo Alto City’s Comprehensive Plan Policy L-1, Goal N-1its purpose is that of
an “Open Space System that Protects and Conserves Palo Alto’s Natural Resources and Natural
Setting”, with a focus on recreation and education in nature. Palo Alto Policy N-1 states that
public open spaces areas should be managed to meet habitat protection goals, public safety
concerns, and low impact recreation needs. Program N-3 elaborates that ecological values must
be protected to realize the full benefits of open space. Any plan that has the potential to affect
ecosystems and biodiversity in natural open space must be scrutinized in this spirit, especially in
Pearson-Arastradero, where the proposed Fire Management Plan Update would directly impact
one THIRD of the preserve area. In our opinion, a fire management / fuel reduction plan in
natural open space should be a subset of a comprehensive conservation plan, and not the
driving force that must be mitigated against.
Palo Alto is currently preparing a conservation plan for the baylands. We think that the
Palo Alto Foothill Open Space merits the same protection as the baylands, and recommend
that the fire management plan be put on hold until a comprehensive multidisciplinary
Open Space/Conservation Management Plan is prepared.
9. PROJECT DESCRIPTION
Identification of potential treatment areas (page 7): The proposed Plan prioritizes access and
aims to provide safe evacuation. While this is indeed the ultimate priority along evacuation
routes, a better management options along internal park habitat and recreation trails should be a
part of a larger conservation plan that may include fuel reduction as a subset of its goals, and
may use less intensive treatments.
9-1 Hand Labor: The Mitigated Negative Declaration states that hand labor is slow and
expensive, but moving slowly can be an asset in habitat restoration and conservation. Hand
labor allows us to proceed slowly giving us a chance to stop if we are causing damage. Rather
than finding we have taken the life of wildlife, especially a rare species (badger, for instance), we
can proceed slowly and carefully, giving ourselves time to find such things along the way.
9-2 Mechanical Treatments. Discing: We agree with the Mitigated Negative Declaration that
discing as a treatment method has several disadvantages, including creating “an excellent
establishment for weedy species, which may be serious fire hazards” also “Surface erosion can
be significant in areas prone to this process.” However, it appears to still be listed as a proposed
treatment, and a mitigation measure related to discing (BIO-6) is in the Mitigated Negative
Declaration. We do not see proposed disced areas in Figures 6 and 7, Proposed Treatment
Areas. We recommend that the documents explicitly prohibit discing.
9-6 Herbicide Application: Describes hand and road-side application from a vehicle. We are
glad that you are not considering aerial application. However, BIO-19, Hazards10 included
mitigation for potential aerial application, we think aerial application should be prohibited.
DISCUSSION OF IMPACTS
A. AESTHETICS
This plan has potential significant impacts on aesthetics and natural visual resources. Some of
these impacts are not addressed by the Mitigated Negative Declaration.
A.a. Substantially degrade the existing visual characters or quality of the site and its
surroundings
In both Foothill Park and Pearson-Arastradero preserve, the experience of a visitor combines
wide scenic views with the aesthetic value and enjoyment of walking through natural low
branches and hanging tree canopies, and observing small plants and animals along the trails
(indeed, some of the restoration and education effort at Pearson-Arastradero focus on small scale
natural value). Mowing and/or removing lower tree branches along nature trails (MeadowLark,
Acorn, Juan Batista de Anza, Bowl Loop) can substantially and negatively affect these resources.
Clearing vegetation from 72 acres along Trappers Fire Road in Foothill Park would also have a
substantial visual impact that is not consistent with the parks natural atmosphere. We believe
either an Environmental Impact Report should be prepared due to the significance of the
aesthetic impact, or mitigation measures for these impacts should be developed and
implemented.
D. BIOLOGICAL RESOURCES
D.a, b, c) The Draft Mitigated Negative Declaration identifies “Potentially Significant” impacts
to biological resources “Unless Mitigation Incorporated”. This should already raise a red flag
when the area in question is valued primarily for its biological resources, and includes a nature
preserve. TRA Environmental Sciences prepared an Environmental Impact Assessment that lists
19 biological mitigation measures. In essence, these measures point to the difficulty of
maintaining a healthy ecosystem while implementing large scale vegetation removal by
mechanical methods, prescribed burning, grazing or field crews.
The TRA assessment points out that some of the methods (grazing, burning, and mowing) have
been shown, in some ecosystems, to enhance habitat value and diversity. The Environmental
Impact Assessment suggests that the proposed update to the plan may in fact ameliorate
conditions for native vegetation as it replaces some fuel removal practices (grading, discing) with
other practices (prescribed burns, grazing). This is based on the assumption that prescribed burns
and/or grazing is an appropriate alternative to low intensity fires that may have occurred in this
area in the past, and that these applications can help native plant species compete against non-
native grasses. While evidence exists to support this general assumption, application area,
intensity, schedule and frequency are of paramount importance and vary among habitats and
ecosystems, and since the primary goal is that of removing fuel, not that of conservation, their
effectiveness in restoring or even maintaining habitat is questionable. We recommend the city
prepare a comprehensive, multidisciplinary ecological conservation plan that incorporates
fuel reduction for fire management rather than mitigates threats to the biological environment.
D.e)“Conflict with any applicable Conservation Plan, Natural Community Plan, or other
approved local, regional or state habitat conservation plan.” There is no conflict only because
there is no plan. There needs to be a comprehensive, multidisciplinary conservation plan for
the foothills.
SPECIFIC MITIGATION MEASURES
BIO-9 includes a modification to the Fire Management Plan Best Practice that requires that a
grazing plan to incorporate protection of drainage and wetlands from the impact of grazing
animals. We would add protection of hillside habitats, taking into consideration aspect and
slope, to the proposed grazing plan, as well as consideration of grazing timing, intensity
and duration.
BIO-19, Hazards10 States “limit areal applications of herbicides to greater than 100 feet from
water resources.” We would absolutely prohibit areal applications of herbicides over foothill
park and the Pearson-Arastradero preserve.
Geology-1 requires a study that identifies all potential erosive soils and the development of an
erosion control plan. We recommend this study should include the mapping and inventory
of native plants on serpentine soils that harbor rare species or have the potential to be
restored to native vegetation.
BIO-2, BIO-3, BIO-4, BIO-5, BIO-6, BIO-7 require biological surveys prior to implementation
of various treatments at various locations. BIO-9 requires mapping, BIO-9, Geology-8, and
Geology-9 require the preparation of grazing plans, Geology-10 requires the development of a
prescribed burn erosion control plan, and Geology-1 requires a study that identifies all potential
erosive soils and the development of an erosion control plan.
These mitigations are more like meta-mitigations, they all call for additional information that
would be necessary to mitigate the impacts of the plan. We recommend the City develop maps
of sensitive habitats and species that would create the basis for an open space/conservation
management plan.
These measures should focus our attention on the need for a multidisciplinary approach that
would consider all the challenges and opportunities involved in human management of natural
landscapes. These challenges and opportunities include enhancement to natural assets and
biodiversity, recreation, erosion control, slope stabilization, and downstream effects of upland
activities, fire management and more.
I. LAND USE PLANNING
b,c,f) We think that the fire plan conflicts with the management of Palo Alto’s natural areas and
may adversely impact nature conservation and enhancement as well as recreation and nature
education. Palo Alto should take a comprehensive, multidisciplinary approach to the
management of its open space.
Contemporary conservation biology focuses on habitat conservation and enhancement as well as
minimization of fragmentation. A sound conservation plan would protect not only special status
species, but also habitat that would support biodiverse ecological communities. In concert with
fuel reduction programs, it would remove accumulated matter in some areas, yet maintain some
brush piles and dead trees for habitat conservation and enhancement. The focus of the plan
would be multi-dimensional, with a larger scope that fire management.
City of Palo Alto
Planning Department
Attention: Kelly Morariu
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Fire-breaks
Dear Mr. Morariu
Arastradero Road Homeowners
6 Arastradero Rd
PortolaValleY,CA,94028 Received
MAR 092.009
Department of PI.anning
& Community EnV1ronment
We are property owners adjacent to the Arastradero Preserve along a common boundary
designated as AC-7 and AC-9 in the Foothills Fire Protection Plan. Over the past years, the
common boundary between our residences and the Arastradero Preserve has been marked
by a disked fire break provided by the City of Palo Alto within the City's property. The
Foothills Fire Protection Plan, now in the public comment period, proposes to replace the
disked firebreak with mowing. We wish to go on record as opposing such a change and
respectfully submit the following factual basis for our opposition.
1. The disked firebreak in the reaches designated AC-7 and AC-9 is now well
established easily renewed annually and shows no prevalence of weed growth. In
particular, the growth of fire-prone Coyote Bush is inhibited by the disking. The
firebreak area is stable and does not produce excessive runoff. With the success of
each disking that carries over to the next year, there is no need for more than one
disking per year. In other words, an effective fire prevention technique is in place.
2. We do not want to risk a loss, such as the Arastradero preserve fire in 1985, where
personal property loss occurred for those unfortunate residents on the Los Altos
border of the preserve. There was no disked firebreak at the time; and Palo Alto
should not wish to expose itself to such liability, either.
3. A retreat to mowing, now that disking has been established, may not produce the nil
consequences of a Negative Declaration. As stated in the Report (p.16-Neg.Dec)
disking is considered to be a proven and effective firebreak. Mowing, by
comparison, may harbor low smoldering fire sources from mower sparks, lightning
or man's activity that can be brought to full flame by freshened wind. Mowing may
well have to be repeated since no growth constraint is involved. In fact on our
neighboring properties, mowing as much as three times a year is sometimes
necessary. Clearly, a second mowing cycle when required will entail costs that, in
total, exceed that of annual disking.
Our appeal in favor of disking is specific in intent and location so that the success of past
years in avoiding a fire threat can be perpetuated. Any other outcome can not meet the
prescribed conditions of a Negative Declaration. We respectfully request that Disking be
designated as the preferred means of maintaining the existing firebreak adjacent to our
properties on the AC-7 and AC-9 reaches of the City's Hillside Fire Protection Plan.
Signed Petitioners: i}~~ I!!a
/rO#f/rlf/t. 13if.SS )? o,g/.::.-~r A-1. b~/S~~\')L 0.· ~I(V\I\.~IR....
,l.L~~ ~~~ /)am.U~ /ld-f-on ~;;;:7r.·iGker /~a//VE /3/1: V'3"QhI\;e 5~ ~+~
1
CEQA Comments Received via City Website and E-mail
(in chronological order)
Foothills Fire Management Plan -
Public Comment Period 2/10/09
thru 3/11/09
03/08/2009 13:38:42 - Receipt No.
62CF563B07859208DEpOrP2E1F9D
Thank you for submitting a comment for the Foothills Fire
Management Plan - Public Comment Period 2/10/09 thru 3/11/09. This
is a copy for your records.
Comment
Name Peter Neal
Email to: pneal1@mindspring.com
Organization
Address 3880 El Centro
City, State,
Zip Palo Alto, CA 94306
Primary
Phone 650-494-6808
Additional
Information
One of the stated goals of the fire plan and mitigation plan
is to =?utf-8?Q?=E2=80=9Cenhance_?= natural resource
ecosystem =?utf-8?Q?health.=E2=80=9D_?= Instead, in an
attempt to fire-proof the foothills, it appears that many of
the proposed procedures have the potential to seriously
harm the ecosystem health. Turning natural wildland into
managed acreage is not an enhancement. It is altering
nature. For example, how can clearing 72 acres of Trappers
Ridge Trail masquerade as helping the ecosystem? Or how
about brushing 30 feet on each side of Page Mill Road?
Aside from the aesthetic issues and potential for soil
erosion, these kinds of actions will most likely result in the
loss of locally important native plants and wildlife habitat.
Managing more than 300 acres in Foothills and Arastradero
is too much. I also feel that many of check mark ratings in
the impact analysis are subjective and arbitrary. For
example, I strongly disagree that the proposed plan will
2
have no impact on the visual character of the area. I
certainly do not want to see a huge barren firebreak when I
am on Trappers Ridge. I support fire prevention--
monitoring picnic fires and observing red flag days--and
clearing around important structures (but bathrooms?) and
maintaining evacuation routes. But we need to keep some
perspective about altering our precious wildlands and
acknowledge the value of those dwindling natural areas.
Receipt Number 62CF563B07859208DEpOrP2E1F9D
Foothills Fire Management Plan - Public Comment Period 2/10/09 thru 3/11/09
03/10/2009 12:14:01 - Receipt No. 45E4C08E079211C2E2RtHmk24421
Thank you for submitting a comment for the Foothills Fire Management Plan - Public Comment Period
2/10/09 thru 3/11/09. This is a copy for your records.
Comment
Name Ann Teegardin
Email to: citizenann@sbcglobal.net
Organization
3
Address
City, State, Zip , CA
Primary Phone
Additional Information I regularly enjoy the areas under consideration here and want them to remain as
natural as possible. Methods of fire management that include disking, grazing or mowing all alter the
natural state drastically and cause great harm to natural, native, plants. The resultant weedy plants are
increased fodder for fires. Please investigate ways of encouraging native plants that naturally do not
burn readily and do not result in quantities of flammable debris. These areas are a treasure to be
preserved in the most ecologically sound way possible. Please do look into this further and find
alternative methods. Thank you.
Receipt Number 45E4C08E079211C2E2RtHmk24421
Foothills Fire Management Plan -
Public Comment Period 2/10/09
thru 3/11/09
03/10/2009 15:27:50 - Receipt No.
4CCB7E610792124FE8OXPLID4F48
Thank you for submitting a comment for the Foothills Fire
Management Plan - Public Comment Period 2/10/09 thru 3/11/09. This
is a copy for your records.
Comment
Name Thomas Harder
Email to: tcharder@juno.com
Organization
Address 1028 Loma Verde Avenue
City, State,
Zip Palo Alto, CA 94303-4031
Primary
Phone 650-494-7598
Additional
Information
Public Safety/ Fire Management should support the Nature
Preserve of Foothills Park, not ruin it. I question the
4
compromises made by increased mowing for islands for
PAFD, the grazing of goats, the use of herbicides and other
such activities cited as needed for support of fire
management. Please preserve the nature preserve in
Foothills Park.
Receipt Number 4CCB7E610792124FE8OXPLID4F48
-----Original Message-----
From: jwo@svpal.org [mailto:jwo@svpal.org]
Sent: Tuesday, March 10, 2009 3:04 PM
To: Council, City
Subject: Foothills Fire Management Plan
March 10, 2009
Dear Council Members:
When the Mitigated Negative Declaration for the Foothills Fire Management
Plan reaches you, we hope the plan does not make its way through the
process without any realization that the fire management plan could do more
damage to our nature preserves, Foothills and Arastradero Parks, that the
fires the plan attempts to mitigate.
Mowing, disking, grazing by goats, cutting chaparral, removing 8 feet of
lower tree branches, and such would leave us at best with unnatural
gardened areas and at worst with weed patches, eroded areas, or dump areas.
The treated area would cover 330 acres in the two parks and there would be
clearing 30 feet from the pavement edges along evacuation routes like Page
Mill, Arastradero, Los Trancos, Sklyline,and the main road in Foothills
park. Clearing would cost $700,000 for 5 years according to the plan
estimate, probably more in reality. And the money would have to come from
grants since there is no room for the project in the regular city budget.
We need a practical plan that clears around our buildings and limits
treatment areas. The parks should not be made the default mitigation area
for the houses outside the park as appears to be proposed.
Thank you.
5
Jean Olmsted
240 West Charleston Road
Palo Alto, CA 94306
jwo@svpal.org
Foothills Fire Management Plan -
Public Comment Period 2/10/09
thru 3/11/09
03/11/2009 11:15:35 - Receipt No.
43BC54DF079851AFB1Jjnk17315D
Thank you for submitting a comment for the Foothills Fire Management
Plan - Public Comment Period 2/10/09 thru 3/11/09. This is a copy for
your records.
Comment
Name Connie Bowencamp
Email to: ruth3539@comcast.net
Organization
Address 201 Ada Avenue #18
City, State,
Zip Mountain View, CA 94043
Primary
Phone 650-814-9212
Additional
Information
I am not a resident of Palo Alto but I do enjoy the
Arastradero open area and have been a guest at Foothills
Park. The proposed Foothill Fire Management Plan calls for
300 feet of cleared space along several trails by disking,
removing chapparel, grazing by goats, and removing trees
as I understand it. It would appear to me that these methods
will make this a treated area rather than a natural area
which is used by many birds and animals. I would be sorry
to see this happen in a City that has a goal to maintain a
healthy environment.
6
Receipt Number 43BC54DF079851AFB1Jjnk17315D
Thank you for submitting a comment
for the Foothills Fire Management
Plan - Public Comment Period
2/10/09 thru 3/11/09. This is a copy for your records.
Comment
Name Claire Elliott
Email to: clairee@acterra.org
Organization Acterra
Address 3921 East Bayshore Rd.
City, State,
Zip Palo Alto, CA 94306
Primary
Phone 650-962-9876 ext. 311
Additional
Information
Acterra Foothill Fire Management Plan Update - Draft
Mitigated Negative Declaration Comments Authored by
Shani Kleinhaus, Ecological Consultant, Acterra Volunteer,
Claire Elliott, Acting Director, Acterra Stewardship, and
William Mutch, Chief Steward, Arastradero Preserve March
11, 2009 PROJECT DESCRIPTION 7.
COMPREHENSIVE PLAN DESIGNATION Foothill Park
may be designated a Public Park, but its spirit and purpose
are NOT of an urban park =?utf-8?Q?=E2=80=9Cwhose_?=
character is essentially =?utf-8?Q?urban=E2=80=9D_?= as
stated in the Draft Mitigated Negative Declaration, but as
stated in Palo Alto =?utf-8?Q?City=E2=80=99s_?=
Comprehensive Plan Policy L-1, Goal N-1its purpose is that
of an =?utf-8?Q?=E2=80=9COpen_?= Space System that
Protects and Conserves Palo =?utf-
8?Q?Alto=E2=80=99s_?= Natural Resources and Natural
=?utf-8?Q?Setting=E2=80=9D,_?= with a focus on
recreation and education in nature. Palo Alto Policy N-1
states that public open spaces areas should be managed to
Foothills Fire Management Plan -
Public Comment Period 2/10/09
thru 3/11/09
03/11/2009 17:09:19 - Receipt No.
9D16FC4A0798529AF2yHOX2B19DA
7
meet habitat protection goals, public safety concerns, and
low impact recreation needs. Program N-3 elaborates that
ecological values must be protected to realize the full
benefits of open space. Any plan that has the potential to
affect ecosystems and biodiversity in natural open space
must be scrutinized in this spirit, especially in Pearson-
Arastradero, where the proposed Fire Management Plan
Update would directly impact one THIRD of the preserve
area. In our opinion, a fire management / fuel reduction plan
in natural open space should be a subset of a comprehensive
conservation plan, and not the driving force that must be
mitigated against. Palo Alto is currently preparing a
conservation plan for the baylands. We think that the Palo
Alto Foothill Open Space merits the same protection as the
baylands, and recommend that the fire management plan be
put on hold until a comprehensive multidisciplinary Open
Space/Conservation Management Plan is prepared. 9.
PROJECT DESCRIPTION Identification of potential
treatment areas (page 7): The proposed Plan prioritizes
access and aims to provide safe evacuation. While this is
indeed the ultimate priority along evacuation routes, a better
management options along internal park habitat and
recreation trails should be a part of a larger conservation
plan that may include fuel reduction as a subset of its goals,
and may use less intensive treatments. 9-1 Hand Labor: The
Mitigated Negative Declaration states that hand labor is
slow and expensive, but moving slowly can be an asset in
habitat restoration and conservation. Hand labor allows us
to proceed slowly giving us a chance to stop if we are
causing damage. Rather than finding we have taken the life
of wildlife, especially a rare species (badger, for instance),
we can proceed slowly and carefully, giving ourselves time
to find such things along the way. 9-2 Mechanical
Treatments. Discing: We agree with the Mitigated Negative
Declaration that discing as a treatment method has several
disadvantages, including creating =?utf-
8?Q?=E2=80=9Can_?= excellent establishment for weedy
species, which may be serious fire =?utf-
8?Q?hazards=E2=80=9D_?= also =?utf-
8?Q?=E2=80=9CSurface_?= erosion can be significant in
areas prone to this =?utf-8?Q?process.=E2=80=9D_?=
However, it appears to still be listed as a proposed
treatment, and a mitigation measure related to discing (BIO-
6) is in the Mitigated Negative Declaration. We do not see
proposed disced areas in Figures 6 and 7, Proposed
8
Treatment Areas. We recommend that the documents
explicitly prohibit discing. 9-6 Herbicide Application:
Describes hand and road-side application from a vehicle.
We are glad that you are not considering aerial application.
However, BIO-19, Hazards10 included mitigation for
potential aerial application, we think aerial application
should be prohibited. DISCUSSION OF IMPACTS A.
AESTHETICS This plan has potential significant impacts
on aesthetics and natural visual resources. Some of these
impacts are not addressed by the Mitigated Negative
Declaration. A.a. Substantially degrade the existing visual
characters or quality of the site and its surroundings In both
Foothill Park and Pearson-Arastradero preserve, the
experience of a visitor combines wide scenic views with the
aesthetic value and enjoyment of walking through natural
low branches and hanging tree canopies, and observing
small plants and animals along the trails (indeed, some of
the restoration and education effort at Pearson-Arastradero
focus on small scale natural value). Mowing and/or
removing lower tree branches along nature trails
(MeadowLark, Acorn, Juan Batista de Anza, Bowl Loop)
can substantially and negatively affect these resources.
Clearing vegetation from 72 acres along Trappers Fire Road
in Foothill Park would also have a substantial visual impact
that is not consistent with the parks natural atmosphere. We
believe either an Environmental Impact Report should be
prepared due to the significance of the aesthetic impact, or
mitigation measures for these impacts should be developed
and implemented. D. BIOLOGICAL RESOURCES D.a, b,
c) The Draft Mitigated Negative Declaration identifies
=?utf-8?Q?=E2=80=9CPotentially_?= =?utf-
8?Q?Significant=E2=80=9D_?= impacts to biological
resources =?utf-8?Q?=E2=80=9CUnless_?= Mitigation
=?utf-8?Q?Incorporated=E2=80=9D._?= This should
already raise a red flag when the area in question is valued
primarily for its biological resources, and includes a nature
preserve. TRA Environmental Sciences prepared an
Environmental Impact Assessment that lists 19 biological
mitigation measures. In essence, these measures point to the
difficulty of maintaining a healthy ecosystem while
implementing large scale vegetation removal by mechanical
methods, prescribed burning, grazing or field crews. The
TRA assessment points out that some of the methods
(grazing, burning, and mowing) have been shown, in some
ecosystems, to enhance habitat value and diversity. The
9
Environmental Impact Assessment suggests that the
proposed update to the plan may in fact ameliorate
conditions for native vegetation as it replaces some fuel
removal practices (grading, discing) with other practices
(prescribed burns, grazing). This is based on the assumption
that prescribed burns and/or grazing is an appropriate
alternative to low intensity fires that may have occurred in
this area in the past, and that these applications can help
native plant species compete against non-native grasses.
While evidence exists to support this general assumption,
application area, intensity, schedule and frequency are of
paramount importance and vary among habitats and
ecosystems, and since the primary goal is that of removing
fuel, not that of conservation, their effectiveness in restoring
or even maintaining habitat is questionable. We recommend
the city prepare a comprehensive, multidisciplinary
ecological conservation plan that incorporates fuel reduction
for fire management rather than mitigates threats to the
biological environment. =?utf-
8?Q?D.e)=E2=80=9CConflict_?= with any applicable
Conservation Plan, Natural Community Plan, or other
approved local, regional or state habitat conservation =?utf-
8?Q?plan.=E2=80=9D_?= There is no conflict only because
there is no plan. There needs to be a comprehensive,
multidisciplinary conservation plan for the foothills.
SPECIFIC MITIGATION MEASURES BIO-9 includes a
modification to the Fire Management Plan Best Practice that
requires that a grazing plan to incorporate protection of
drainage and wetlands from the impact of grazing animals.
We would add protection of hillside habitats, taking into
consideration aspect and slope, to the proposed grazing
plan, as well as consideration of grazing timing, intensity
and duration. BIO-19, Hazards10 States =?utf-
8?Q?=E2=80=9Climit_?= areal applications of herbicides to
greater than 100 feet from water =?utf-
8?Q?resources.=E2=80=9D_?= We would absolutely
prohibit areal applications of herbicides over foothill park
and the Pearson-Arastradero preserve. Geology-1 requires a
study that identifies all potential erosive soils and the
development of an erosion control plan. We recommend this
study should include the mapping and inventory of native
plants on serpentine soils that harbor rare species or have
the potential to be restored to native vegetation. BIO-2,
BIO-3, BIO-4, BIO-5, BIO-6, BIO-7 require biological
surveys prior to implementation of various treatments at
10
various locations. BIO-9 requires mapping, BIO-9,
Geology-8, and Geology-9 require the preparation of
grazing plans, Geology-10 requires the development of a
prescribed burn erosion control plan, and Geology-1
requires a study that identifies all potential erosive soils and
the development of an erosion control plan. These
mitigations are more like meta-mitigations, they all call for
additional information that would be necessary to mitigate
the impacts of the plan. We recommend the City develop
maps of sensitive habitats and species that would create the
basis for an open space/conservation management plan.
These measures should focus our attention on the need for a
multidisciplinary approach that would consider all the
challenges and opportunities involved in human
management of natural landscapes. These challenges and
opportunities include enhancement to natural assets and
biodiversity, recreation, erosion control, slope stabilization,
and downstream effects of upland activities, fire
management and more. I. LAND USE PLANNING b,c,f)
We think that the fire plan conflicts with the management of
Palo =?utf-8?Q?Alto=E2=80=99s_?= natural areas and may
adversely impact nature conservation and enhancement as
well as recreation and nature education. Palo Alto should
take a comprehensive, multidisciplinary approach to the
management of its open space. Contemporary conservation
biology focuses on habitat conservation and enhancement as
well as minimization of fragmentation. A sound
conservation plan would protect not only special status
species, but also habitat that would support biodiverse
ecological communities. In concert with fuel reduction
programs, it would remove accumulated matter in some
areas, yet maintain some brush piles and dead trees for
habitat conservation and enhancement. The focus of the
plan would be multi-dimensional, with a larger scope that
fire management.
Receipt Number 9D16FC4A0798529AF2yHOX2B19DA
NOTE: THE ABOVE COMMENT IS A DUPLICATE OF A LETTER
SUBMITTED MARCH 11
11
END
“Comments from Stu Farwell” (Los Altos Hills Co. Fire Dist.): RECEIVED VIA
CAROL RICE / FEB. 23, 2009
The apparatus that responds from this station is a Type III Engine Company. This is an
apparatus that is primarily designed to respond to wildland fires instead of structure fires.
This is similar to the types of companies used by major wildland agencies.
The station provides an initial attack capability to an area that involves about 25 square
miles of urban-wildland interface area. There are approximately 150 dwellings in the
area, but that is not the primary risk. The fire history of this specific area is relatively
free of major events in the past decades. The last reported major fire in the vicinity of the
upper foothills was in 1912. Significant fires in the lower foothills (primarily light fuels)
occurred in 1985, 1992, 2000 and 2007.
However, that one factor creates an impact upon existing fuel loads. The lack of major
fires in the past has resulted in fuel densities that may be ready to support a wide area
fire. It has been estimated that the medium and high density fuels are about three times
their normal density.
The secondary response units into this area are deployed from the “El Monte” fire station
of Los Altos Hills County Fire District (LAHCFD)Santa Clara County Fire located to the
north and the Palo Alto Stations #2 and #5. The County (LAHCFD) Fire Station is
equipped with Type I and Type IIIV engines. Currently there is no direct link to this
station in the dispatching of equipment. Depending upon who reports an emergency in
the area the call could go directly to the City of Palo Alto or it could be routed through
the Santa Clara County Communication Center and Palo Alto would then be notified.
The standard response into this area varies upon the level of dispatch. On medium or high
dispatch days the Palo Alto Fire Department responds Engine 8 to reports of wildland
fires and supports it with another Type III (3 personnel) that is cross staffed by the truck
company from Station #6 on the Stanford Campus, one Type I from Station #2 (3
personnel), 2 Type IV cross-staffed patrol units from Stations #2 and #6 (6 personnel),
one Paramedic ambulance from Station #2 (2 personnel) and one Battalion Chief from
Station #6.
Furthermore, the dispatch system provides a brush unit from the (LAHCFD)Santa Clara
County El Monte Fire Station in Los Altos Hills at Foothill Community College (4
personnel from 1000-1900 hours) and can respond an additional 4 Type I’s (12
personnel) and 3 Type IIIV Brush units (9 personnel). Lastly, the system has the depth to
provide additional resources from other mutual aid entities in the same area (e.g. Cal Fire
Ranger Unit resources located in Cupertino and San Martin). These include additional
Type III units (3 or more), air assets, hand crew resources, bulldozers and command staff
to complete an overhead requirement in the event of a major fire. Other Type 1, Type III
and Type IV resources may be made available through the Santa Clara County Mutual
Aid System.
The City of Palo Alto does currently not have an adopted Standards of Cover document,
but operates with an informal response goal of 5 to 6 minutes for attendance of at least
90% of its calls for service. The department also provides paramedic (advanced life
support – ALS) response to the basic built out portion of the city within 8 minutes for at
least 90% of those types of calls (these response goal benchmarks are exclusive of the
foothills area). Station 8 has not normally been considered an ALS resource. In the past 2
years a priority has been established to staff Engine 8 with an ALS resource whenever
possible.
The staffing for the station is provided in the overtime budget. Last year the amount set
aside to provide coverage was $200,000.
The City of Palo Alto
Planning Department
250 Hamilton Ave.
Palo Alto, CA 94301
Attention: Kenneth Dueker, City Manager's Office
i!l,LJO, C~\ or-FleE
240 W. Charleston Rd.
Palo Alto, CA 94306
650-493-3468
March 9, 2009
Re: Comments on Mitigated Negative Declaration, Foothills Fire Management Plan
Dear Kenneth Dueker:
The following comments are intended to supplement those submitted by my wife, Jean 0 Imsted, in a separate
letter. My comments are confined to proposed fire-management treatments along evacuation routes and
containment areas in the Fire Management Plan for Foothills Park. These places are where the proposed
treatments most significantly affect the ecology of the Park.
Evacuation routes.
F.EI Page Mill Road. Only part of this route adjoins Foothills Park. Does the 9.54 acres indicated
for this area include only",Foothills Park land, or does it include both sides of the road along the entire
length indicated on Figure 6 of the Fire Management Plan Update? In any case, the negative impacts of the
treatment on the aesthetic and ecological values along this corridor are substantial. One of the few positive
results would be the removal of French, Scotch, and Spanish brooms. Treatment would likely be costly and
difficult.
F.E2 Park Road. Treatment of the 5.96 acres along this major road in the Park would seriously
impact aesthetic and ecological values within the Park and would likely compromise some ofthe invasive-
plant work done by Park volunteers along parts of this corridor. Optimal treatments for fire safety often
conflict with rather than supplement or augment the treatments for restoration of native plants.
F .E3 Park Northwest. Problems related to treatment of this 0.57-acre area are similar to those along
other roads in the Park ..
F .E4 Park Northeast. Potential conflicts of values along this 1.2I-acre route are significant, owing
to the presence of some native forbs, notably including the rare dwarf owl's clover, Tryphysaria pusilla, near
the Panorama Trail crossing.
F.E5 Towle Campground. In the past, work along this route through Wildhorse Valley, including
the sediment-catchment basin near Towle Camp, Chiefly by Park and Utilities staff, has resulted in the
introduction of undesirable exotic invasive plants, notably stinkwort (Dittrichia graveolens), milk thistle
(Silybum marianum), Italian thistle (Carduus pycnocephalus), yellow starthistle (Centaurea solstitialis),
purple starthistle (Centaurea calcitrapa), and poison hemlock (Conium maculatum). Seeds probably were
introduced on the wheels and undercarriage of vehicles and other equipment. The problem was further
exacerbated by untimely mowing that resulted in the growth of very short yellow starthistle plants having
an unusual abundance of seed-producing flower heads.
F.E6 Southwest comer of. On figure 6 ofthe Fire Management Plan Update, none of this route is
adjacent to Foothills Park. Why is the 6.07-acre area included in mitigation area charged to Foothills Park?
Containment areas.
F.CI Trappers Trail. This 72.51-acre area along the crest of Trappers Ridge constitutes the most
serious impact on the native vegetation of the Park of all the treatment areas. It is also an area cleared many
times in the past, presumably to contain wildfires in the park to one side of the ridge. Although the proposed
width of the cleared zone is 600 feet (300 feet on each side of the road), it is actually variable, depending on
the local topography and is less than 100 feet wide above the junction with the Madrone fire trail (see figure
6) Incidentally, why is the Madrone fire trail not included as a containment area? Maintenance of the
Trappers Ridge fuel break in recent years has involved considerable widening but also abandonment of
earlier cleared areas some distance from the ridge top. Not all plants other than forbs and grasses were
cleared. Scrub oaks, coast live oaks, and madrones, were spared, although the lower branches of these trees
were removed.
The result of all this clearing has been the permanent(?) removal of some chaparral taxa, notably
bush poppy (Dendromecon rigida) and Ceanothus (both C. cuneatus var. cuneatus and C. oliganthus var.
sorediatus) and the proliferation of yellow and purple starthistles as well as the introduction of stinkwort
(Dittrichia graveolens) and plumeless thistle (Carduus acanthoides). On a more positive note, the rare and
interesting forb, divaricate Phacelia (P. divaricata), manages somehow to survive all the clearing and may
be found blooming at all times of the year. Is all this costly treatment really necessary? The visual and
ecological impacts are an overwhelming alteration of what is supposed to be a nature preserve.
F.C2 South of Pony Tracks Road and F.C3 North of Pony Tracks Road. Many of the comments
above for Trappers Trail apply also to these much smaller areas.
F.C4 Bobcat Point. I could say, this one really got my goat. The use of goats to maintain a
drastically altered and ecologically inappropriate plant community is really too much. The map (figure 6)
is erroneous in this area, and the proposed treated area, if it includes a 300-foot-wide zone along the Park
boundary, is at least double the 5.28-acre area indicated. Apparently this is an attempt to protect residences
just outside the Park boundary. This would be accomplished by changing an unusual and interesting mixed
chaparral and woodland plant community to a grassland containing islands of trees and shrubs. The
remaining plants might not include rare and interesting plants now present, such as chaparral currant (Ribes
malvaceum), previously nearly extirpated by over-zealous and under-supervised trail maintenance, oso berry
(Oemlaria cerasijormis), and red-flowering currant (Ribes sanguineum, very unusual in such an
environment). Although there is much chaparral elsewhere in the Park, the plant assemblage here is almost
unique in that it represents this type of vegetation on a north-facing slope at a relatively low altitude for
chaparral in the region.
On another note, the treatment proposed here would involve the logistically difficult and costly use
of goats in an area where denudation by the goats would result in accelerated erosion on slopes that locally
exceed 50 percent. In short, don't do it!
F.C5 North of entry gate. The situation here both differs from and resembles that at Bobcat Point.
This 3.47-acre area constitutes a real woodland (no chaparral,justtrees and some shrubs as understory) but,
like Bobcat Point, it is on a north-facing slope adjacent to residences just outside the Park boundary.
Elsewhere in the Fire Management Plan Update, the type of vegetation here is assigned a fairly low burning
potential. In this situation, however, where there are houses nearby, it is deemed necessary to eliminate
understory shrubs more than 18 inches tall. and to eliminate the lower branches of the trees. Again, the Park
apparently is the default mitigation area for places outside the park.
F.C6 VaUey View Fire Trail. I understand that the top ofthis ridge is to be maintained as a fire road
rather than as a minor fuel break. Even as a fire road, care should be taken to prevent introduction of yellow
starthistle seeds by vehicles. Oaks along the edge of the fire road should be protected; two of these oaks are
unusual hybrids of scrub and valley oaks and should not be removed or damaged by any maintenance
operations.
~¥~
Franklin H. Olmsted
Foothills Fire Management 14
February 24, 2009 Draft Notes for Park and Recreation Commission Meeting
Jean Olmsted: I and my husband and a lot of other volunteers spend a lot of time in
Foothills Park removing invasive plants. We know less about Arastradero. This fire
plan scares me. We need your help.
Why? Because the things you do to prevent fires, things like mowing and disking and
grazing and cutting tree limbs and so forth are things that can destroy a nature
preserve. If lucky, you might wind up with a garden, but that is not natural. Using the
plans figures, this fire prevention scheme if followed will cost for five years $700,000
(which Palo Alto's city budget does not have) and treat 330 acres in the two parks. It is
a huge project that probably would cost a lot more than is estimated. And our precious
parks will be damaged. This plan does not recognize that the purpose of the parks is to
save natural areas.
I have been learning about some fire fighting history. The Indians managed well with
lots of small 'fires that helped them keep grassy areas that they wanted. I remember
Smokey the Bear and the era where we tried to stop all wildland fires and were pretty
successful. But then the fires we did have were huge, impossible to stop, and even
killed firefighters. So now we concentrate our wildland fire fighting on saving the homes
of people who build in wildland areas. Perhaps that is what we should be doing here.
As for this plan, it is difficult to understand why certain areas were chosen for treatment.
And some of the ideas do not fit with the on-the-ground situation. My husband is going
to tell you about one sample of that kind of problem. The plan and the Mitigated
Negative Declaration somehow surfaced for public view together on February 10. I was
surprised that the sources used in the EIR were so limited. The specific fire mitigation
proposals must have come from reference #4 (The Plan) and more on the ground
experience would have helped.
The easiest way to get a grip on what is proposed is to look at the tables. I found
pages 8-11 of the Draft Mitigated Negative Declaration helpful because those tables
include for identified purposes the place, area, and treatment method for Foothills Park.
I could not find the same summary information for Arastradero. The Arastradero tables
are in the Plan starting with pg 47 but they are interspersed with Foothills Park and
other information. The cost estimates are in The Plan starting on page 67.
And here are a few if my odds and ends. I am wondering whether it is necessary to
define a Foothills Park restrooms as defensible space. It is concrete. Might be cheaper
not to clear and then fix it after a fire with the money saved. Clearing perimeter space in
Arastradero 300 feet from park boundaries in deSignated places sounds pretty drastic.
And what about clearing 30 Feet on both sides of the pavement edge of evacuation
routes? That means Page Mill, Arastradero, Los Trancos, Skyline, and I think the main
road inside Foothills Park. A lot of these are private property whose owners might not
agree.
Just remember, it makes no sense to save the parks from fire if you have destroyed
them by saving them. Consider a reduced plan where you define evacuation routes and
encourage everyone to prepare their own property.
DRAFT
February 24, 2009 Draft Minutes 1
MINUTES
PARKS & RECREATION COMMISSION
February 24, 2009
City Hall
250 Hamilton Ave
Commissioners Present: Deirdre Crommie, Joel Davidson, Sunny Dykwel, Carl King, Paul
Losch, Pat Markevitch, Daria Walsh,
Commissioners Absent:
Others Present: Council Liaison Espinosa
Staff Present: Greg Betts, Catherine Bourquin, Lester Hodgins, Rob de Geus,
Donald Piana
I. ROLL CALL CONDUCTED BY: Catherine Bourquin
II. AGENDA CHANGES, REQUESTS, and DELETIONS: Item 3, Presentation by
PABAC will not be presented tonight. Staff de Geus and Commissioner Crommie will
provide a short update on this topic. Item 5 will not be an Action item but the
Commissioners comments will be taken and submitted with the staff report that will go to
Council from Kenneth Dueker, City Managers office.
II. ORAL COMMUNICATIONS: Kevin Coleman, spoke on the lack of gym space in Palo
Alto. He would like to see attention put on the short and long term impacts of this problem.
IV. BUSINESS:
1. Approval of Draft Minutes of January 26, 2008 regular meeting – The Draft
Minutes of the January 26, 2009 regular meeting were unanimously approved as
written. Approved 7:0
2. Welcome new City Council Liaison Sid Espinosa - Council Member Espinosa was
welcomed as our new City Council Liaison for the Parks and Recreation Commission.
3. Informational presentation from Palo Alto Bicycle Advisory Committee (PABAC) –
Staff de Geus informed the commission that Richard Swent who was to speak tonight
had back surgery and was unable to make it to tonight’s meeting. Staff de Geus spoke
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February 24, 2009 Draft Minutes 2
with Mr. Swent and shared with the Commission some of the points of interest that
PABAC is involved with. Among other interests PABAC has been involved in
improving bicycle access to the Baylands. They have been working with VTA on the
concept of a Highway 101 underpass/overpass to the Baylands in South Palo Alto.
Commissioner Crommie also advised the Commission that PABAC is also interested in
the existing Adobe Creek underpass and expanding the open hours of the underpass for
pedestrians and bicyclists. PABAC will be invited to the March 24th regular meeting.
4. Discussion with Anne Cribbs on the Senior Games – Anne Cribbs came to the
Commission to provide an update on the 2009 National Summer Senior Games. The
count down has started and there is only approximately 150 days left until the games
commence. The official dates for the senior games are August 1 – 15, 2009. The
expectation is 12,500 athletes will participate in the games. There are 4000 volunteers
needed to put this event on. Anne Cribbs provided a demonstration on using the Senior
Games website to register volunteer Commissioner Chair Markevitch as the first to sign
up. The website to register for these volunteer opportunities is
www.2009seniorgames.org. The Commissioners were given time to ask questions
following the presentation. Commissioner Davidson challenged the Commission to come
up with a total of 250 volunteers. A motion was made by Commissioner Davidson and
seconded by Commissioner Crommie.
Motion: To have the Parks and Recreation Commission cooperate together to achieve a
250 volunteer quota for the 2009 National Summer Senior Games.
Approved 7:0
5. Approval of a Recommendation to City Council for the Adoption of a “Foothills Fire
Management Plan” – Staff de Geus reminded the commission of the item change at the
beginning of the meeting referring to the staff memo he provided correcting the title of
the item. The Commission was asked for a recommendation to City Council but instead
they are only being asked tonight to provide comments, and notations of errors or
omissions on the draft plan. Staff will capture all the Commissioners comments in the
minutes and the minutes will be attached to the Staff report that goes to Council in April.
Kelly Morariu, Interim Deputy City Manager, provided the Commission with a brief
update on the purpose of the Foothills Fire Management Plan. She stated that the plan
came about from a discussion with the City Council during the 2008 city budget process.
The fire safety in the foothills and the staffing of fire station 8 were discussed and a
request from City Council was made to the City Manager’s Office to have a fire
management plan created for the foothills area in Palo Alto. The key players for this plan
were introduced, Carol Rice and Cheryl Miller consultants of Wildland Resource
Management, Ken Drueker, Police Department on special assignment for the City
Managers Office, Lester Hodgins, Supervisor Open Space and Greg Betts, Interim
DRAFT
February 24, 2009 Draft Minutes 3
Director of Community Services. A PowerPoint presentation was provided by the
Wildland Resource Management consultants focusing on the information in the Wildland
Fire Risk Assessment and mitigation draft that was provided to the Commission and
Public.
The Fire Management Plan Update addresses the following key items:
• Fire hazard assessment
• Regional evacuation routes
• Review of municipal ordinances
• Staffing of Station 8
• Wildland Fire Management Recommendations and Mitigations
• Updates to Pearson-Arastradero Trails Master Plan and Foothills Trail Maintenance
Plan
• CEQA documentation
• Implementation plan and potential funding
Oral communications followed the presentation:
Jean Olmsted, 240 West Charleston, Palo Alto – Mrs. Olmstead who is a volunteer at
Foothills Park removing evasive plants spoke on how she feels that the plan is designed
to prevent fires but will destroy the nature preserve. The plan calls to treat 330 acres
“but we will be lucky if we are left with a garden” she said. The prevention treatments
need to be reconsidered so the natural areas are not destroyed.
Franklin Olmsted, 240 West Charleston, Palo Alto – Mr. Olmsted provided the
Commission and Public with some handouts of a map and a list of plants that are in an
area that is on the treatment plan for the Fire Management Plan. His concern of the area
is that the area is very steep and in the area of the chaparral are very rare species. The
treatment suggested in the plan would wipe out these rare species and change the unique
ecology that only occurs in this particular area of the park. He would like to see
something else be done in that area of the park.
Interim Deputy City Manager Morariu reported that the staff report that will be going to
Council will have the Foothills Park and Arastradero Preserve specifically mentioned in
the report and the comments and concerns from the Parks and Recreation Commission
will be included.
Commissioners Questions and Comments:
Commissioner Davidson – Commissioner Davidson was concerned with the draft
mitigated negative declaration.
DRAFT
February 24, 2009 Draft Minutes 4
1. Under BIO–1, what is meant by “the legal consequences of take of protected
species or habitat”?
Answer by Consultant Rice: She said that it was a Fish and Game technical
jargon that they use.
2. Why do chemical herbicide treatments and not biological treatments get more
attention in the report?
Answer by Consultant Rice: The concern is on the eucalyptus stumps and the
sprouting, they felt that herbicides would be a more affective treatment.
Commissioner Davidson would like to see an emphasis put on biological
treatments in the report.
3. The words “Not anticipated” come up a lot in the report. Would like to see more
of a reason why it is not anticipated.
4. The area around Los Trancos has a lot of eucalyptus trees, neighbors in that area
would like to know how to have them removed. Is this part of our jurisdiction
and how does the City intend to assist with eucalyptus removal? Is the report
going to address this problem?
Answer by Consultant Rice: The treatments prescribed are within the Palo Alto
property lines. There will be collaboration with other jurisdictions that are
impacted by potential fire hazard areas.
5. Why does noise in that area not reflect a problem in the mitigation report?
Answer by Consultant Rice: There is a threshold requirement, and the
anticipated level of noise from machinery was not determined to reach that
threshold.
Commissioner Dykwel –
1. Make sure the report addresses the ingress and egress routes for the neighbors that
would be impacted if there was a fire. She wanted to ensure that
communication was implemented with all concerned residents.
2. That an emphasis is placed on the community for regional cooperation for
evacuations.
3. Ensure that the plan does not have any adverse impacts on the natural
environment of the nature preserves.
Answer: Consultant Rice referenced the Draft Mitigation Declaration and noted
the BIO’s section references any concerns with plant species, wildlife, etc.
Commissioner Walsh – Commissioner Walsh thanked everyone involved in the report
and to the residents that came forward today with their comments.
1. How will the Public’s and the Commission’s comments be incorporated into the
plan? And what is the date to have them in by?
Answer by Consultant Rice: It is her understanding that the comments, suggestions
will be sent in a list form asking the consultants to modify the plan
DRAFT
February 24, 2009 Draft Minutes 5
and include them before the final adoption by Council in April. All comments
should be received by March 11, 2009.
2. The question relates to the mowing of the sides of the small trails. If you have
to mow every year, wouldn’t it make sense to just make the mowed fire breaks
accessible to the public as trails?
Answer: Staff Betts replied by given a little history on how trails were
developed. In Pearson Arastradero Preserve, the trail system is 10 miles that can
be safely patrolled by staffed rangers, and in Foothills Park there are 15 miles of
trails that can be safely patrolled by staffed rangers.
Commissioner Losch –
1. If we did nothing on a scale of 1 – 10, 10 being the highest risk, where do these
two parks fall, if we maintain the status quo?
Answer by Consultant Rice: The State looks at the building codes and the park preserves
are in the 75% of that code. The containment area is the most concern. By accepting this
plan the approximate percentile that you will be improving would be about 50% in
relation to the original 75%.
2. If there is an incident, are we reducing the degree of havoc?
Answer by Consultant Rice: We would be reducing it dramatically. Commissioner
Losch wanted to emphasize that if we show that there will be a dramatic decrease by
using the treatments in the plan, there will be those who will argue the necessity of
keeping Fire Station 8 open.
3. This is a $700,000 project, how much does it cost to raise $700,000?
Answer by Deputy City Manager Morariu: She said it will depend on the structure; it
will be a multi-pronged plan and we will be partnering with regional stakeholders.
The regional areas will have their own fire plans in place in order to make the process
easier to apply for grants.
Commissioner Crommie –
1. Where would the fire most likely start from?
Answer by Consultant Rice: We targeted the ignition source in our report,
BBQ’s were focused on, road side fires were main concern. She added most
fires are human caused.
2. Commissioner Crommie would like to see the BBQ’s removed from residents
homes that impact the areas closes to the fence line then to have the wildlife
habitat be impacted by mowing or grazing.
Answer by Consultant Rice: Residents are supposed to be doing there own fire
management program. The fire department regulates this and does home site
inspections.
3. Commissioner Crommie questioned the error in prioritization.
Answer by Consultant Rice: She replied that life, property and resources are
used universally to prioritize a fire plan.
DRAFT
February 24, 2009 Draft Minutes 6
4. Commissioner Crommie expressed her concern over sudden oak death; she
wanted to double check that the processes for the treatments would not increase
the chance of contamination.
Answer: Consultant Rice suggested a vehicle and equipment washing machine be
included in the grant proposal to prevent seed spreading and any contamination of
diseases.
Commissioner King -
1. How does it get implemented by the actual fire department?
Answer by Officer Ken Dueker: It doesn’t involve just the Fire Department; it
involves the Police, Fire and Open Space and Parks departments. This is a
multi-faceted problem. The plan is technical and isn’t a reference document for
the fire department to rely on. We’re hoping to spawn interagency cooperation,
so we can solve the gaps that have been identified in this Fire Management
Plan.
2. Commissioner King shared his concern that he did not see the metrics for how the
City will determine how best to use limited resources to implement the plan. For
example the plan provided an example of grazing vs. mowing but it was not clear
what numerical analysis will be used to determine which of the recommendations will
be implemented. Commissioner King also asked about how the environmental costs
get factored into the decision making process?
Answer by Consultant Rice and Miller: During the implementation process there
will be an implementation team who will investigate the options that have
been highlighted in the Draft Mitigated Negative Declaration. Once there has
been a determination, the recommendations and actions have to be followed. There
are some dollars associated with this because of the monitoring costs that are
involved.
Interim Deputy City Manager Morariu informed the commission that following the
close of comments to the Foothill Fire Management Plan staff in planning will walk
through with the concerned parties who submitted comments. Often times the plan
will change slightly. Any changes and recommendations will be incorporated. We
will probably sit down with the Olmsteds and look into their concerns.
Commissioner Markevitch - Commissioner Chair Markevitch had suggested at a
previous meeting that the BBQ’s at Foothill Park be changed to propane. She did not see it
in the report.
1. Commissioner Markevitch would like to see converting the BBQ’s to propane be
considered as an option for Foothill Park. This would eliminate the potential fire
hazard from hot coals and the chance of them blowing out.
Council Liaison Espinosa –
DRAFT
February 24, 2009 Draft Minutes 7
1. Council Liaison Espinosa inquired if the report would be coming back to the
Commission to flush out items such as the cost benefits vs. environmental impacts.
Answer by Interim Deputy City Manager Morariu: She responded that it would
not, unless directed by Council to. Once the implementation of the plan was
underway, there will be a lot of dialogue occurring and she could see engaging
the Commission in this process. We are still working on how that strategy is
going to work.
2. He added that he was impressed on how much outreach has been done. He also
wanted to recommend that when it comes before the Council it is presented
with how we’ve been doing outreach, what will be different and what we will be
doing. The process in which the plan was developed doesn’t need to be
the main focus. Station 8 – the “big elephant in the room”, will probably be a big part
of the discussion, so being prepared for that discussion will be helpful.
Interim Deputy City Manager Morariu responded by agreeing and her feeling
was that the plan was the starting point and the focus on the implementation
will require a lot of discussion.
6. Agenda setting – Review suggested topics for consideration at future meetings – The
Commission engaged in a discussion on topics for future meetings. Staff de Geus
suggested that the Commission first reaffirm the existing priorities. Then, once the
priorities are reaffirmed, concentrate on the additional items that were suggested and see
where they fit in with the priorities. The Commission can then have two or more
Commissioners choose topics of interest that they will work on and bring to the
Commission when the item is ready for a meaningful and productive discussion.
After some discussion on the existing priorities a motion was made by Commissioner King
and seconded by Commissioner Losch:
a. Playing Areas –
A. Develop a field allocation policy necessary to meet the recreation and non-
recreation demands of our residents at a fair and reason cost.
B. Engage in a CSD Strategic Planning process
1. Analysis of existing conditions and capacity of CSD programs, services and
facilities.
2. Analysis of community perspective on CSD programs, services and facility needs
for the future, and
3. Development of specific strategies and actions to best meet these needs within
realistic budget constraints.
b. Open Space
1. Provide citizens and staff clear statements and guidelines on balancing
recreational uses with habitat preservation in Open Space.
DRAFT
February 24, 2009 Draft Minutes 8
c. Culture of Fitness
1. Encourage the citizens and employees of Palo Alto to embrace a healthier
lifestyle through increased physical activity.
d. Partnership
1. Identify and compile a comprehensive list of all partnerships pertaining to the
Parks & Recreation Department with an eye towards forging new ones.
e. Palo Alto as a Magnet
1. Understand Palo Alto’s role and cost structure with regards to providing Parks
and Recreation services to residents and non-residents.
Motion: To have the following changes reflected in the Commissioners 2009 Priorities.
1. Remove from Playing Areas “B.” Engage in a CSD Strategic Planning
process
2. Change the title “a. Playing Areas” to “a. Reserved recreational facilities”.
3. Move “e. Palo Alto as a Magnet” under “a. Playing Areas” as “B”
4. Make “Engage CSD strategic planning process as priority “e”.
Approved 7:0
Items to be included as potential agenda items on the work plan were identified as follows:
• Overview of Open Space and Parks Division operations – Opportunity to introduce
Rangers and CIP project coordinator.
• Access to Baylands – move to March meeting
• Informational presentation on update of CIP funding/projects
• Greer Park renovation – CIP project
• The policy on the terms of office for the Commission – Commissioners King and
Davidson.
• Creek/Urban trails – Commissioners Dykwel and Crommie
• Public Art in Parks – Chair Markevitch will be meeting with the Chair of the Art
Commission to discuss how art is placed in parks.
• Parks and Recreation Commission and PAUSD liaison – Commissioner Losch and
Walsh will work on formalizing a plan and then meet with Chair Markevitch.
• Revisiting recreational opportunities for dog owners – Commissioners Walsh and Losch
• Middle School Athletic program and policy – Commissioners Walsh and Markevitch
• Community Garden opportunities – Commissioners Davidson and Crommie
• Open Space Vision statement – Commissioners Walsh and Crommie
• JCC/Cubberley Gym transition – Informational
V. COMMENTS AND ANNOUNCEMENTS
1. Adopt-A-Park list – Traditionally whoever got the information to Catherine first had
their pick of parks. Return your forms to Catherine.
2. CPRS conference is next week March 3rd – 8th.
DRAFT
February 24, 2009 Draft Minutes 9
3. Staff de Geus informed the Commission that he received a letter from a concerned
user of the impact that will take place during the Greer Park renovation. Staff is
working on responding.
4. Commissioner Davidson remarked on the documentation that the Commission
receives is sometimes unreadable.
5. Commissioner Davidson announced that staff Minka Van der Zwaag is working on
Earth Day. He would like to have a heads up when programs are coming up. Staff
de Geus said he would send out the work schedule for Earth Day.
6. Commissioner Davidson formally apologized to the Commission for his remarks on
the Commission’s work load at last months meeting.
7. Commissioner Crommie would like to have a laser light pointer available for
presentations.
VI. TENTATIVE AGENDA FOR MARCH 24, 2009 REGULAR MEETING:
1. A public meeting for Seale and Greer Park will be on Wednesday, March 11th.
Commissioners will receive notification to follow the Brown Act laws.
March 24, 2009 Tentative Agenda
- PABAC presentation
- Lytton Plaza Project review and recommendation to Council to adopt a Park
Improvement Ordinance for the Project Plan.
- Presentation on Recreational Aquatic Program with staff Annie Bunten
VII. ADJOURNMENT
Adjourned at 11:02pm