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HomeMy WebLinkAboutStaff Report 5.C 9/10/2012 AttachmentTrestle Rehabilitation Project Recirculated Environmental Assessment and Initial Study/Proposed Mitigated Negative Declaration Revised and Recirculated August 8, 2012 Prepared for: City of Petaluma, 11 English Street, Petaluma, CA 94952 Prepared by: GHD Inc., 2235 Mercury Way, Suite 150, Santa Rosa, CA 95407 Contents 1. Project Information 1 1.1 Project Background 1 1.2 Purpose and Need for the Proposed Action 1 1.3 Proposed Action/Project Description 2 1.4 Surrounding Land Uses and Settings 6 1.5 Other Public Agency Approvals 6 1.6 Alternatives to the Proposed Action 7 2. Environmental Factors Potentially Affected 15 2.1 Determination 16 I. Aesthetics 17 II. Agriculture and Forest Resources 19 III. Air Quality 21 IV. Biological Resources 24 V. Cultural Resources 34 VI. Geology and Soils 42 VII. Greenhouse Gas Emissions 46 VIII. Hazards/Hazardous Materials 48 IX. Hydrology and Water Quality 51 X. Land Use and Planning 55 XI. Mineral Resources 58 XII. Noise 59 XIII. Population and Housing 66 XIV. Public Services 67 XV. Recreation 68 XVI. Transportation/Traffic 69 XVII. Utilities and Service Systems 72 XVIII. Mandatory Findings of Significance 74 2.2 Other Required Analysis for NEPA 76 3. Preparers 79 4. Source References 80 City of Petluama Trestle Rehabilitation Project August 2012 Recircuated EMS Proposed MND 0205511002 GHD I Table Index Table 1-1: Trestle Components, Current Condition, and Planned Treatment 3 Table IV -1: Biological Communities within Project Area 25 Table XII -1: Vibration Source Levels for Construction Equipment 61 Table XII -2: Construction Equipment 50 -Foot Noise Emission Levels 63 Figure Index Figure 1 Vicinity Map g Figure 2 Trestle Images 10 Figure 3 Site Plan 12 Figure 4 Typical Bent 13 Figure 5 Conceptual Bank Stabilization Alternatives 14 Appendices A Mitigation Monitoring Program B Jurisdictional and Habitat Maps C SpeGi ,l Status Spool° Biological Resource Assessment D Comment Letters City of Petluama Trestle Rehabilitation Project August 2012 Recircuated EMS Proposed MND 0205511002 GHD H Introduction to Recirculated Environmental Assessment and Initial Study/Proposed MND The Trestle Rehabilitation Proiect Environmental Assessment and Initial Study/Proposed Mitigated Negative Declaration (EA and IS/Proposed MND) was circulated for public and agency review from June 12 to July 11, 2012, by the State Clearinghouse and from June 13 to July 13 by the City of Petaluma During that time four comment letters were received, which are included as Appendix D. Changes have been made to the document in response to the comments received. One new potential impact (to nesting migratory birds), and corresponding mitigation, has been included in Section IV Biological Resources. Therefore, the EA and IS/Proposed MND is being recirculated, in accordance with Section 15037.5 of the CEQA Guidelines, from August 8 to September 6, 2012. Additional information, in response to the comments, has been provided for clarification throughout this document. In addition, the potential staging area to the east of the Trestle has been removed from the Protect. Changes are shown as underline and strikeout. E 1. Project Information Project Title: Lead Agency Name: Address: Contact Person: Phone Number: Project Location: Assessor Parcel Number: Project Sponsor's Name: Address: General Plan / Central Petaluma Specific Plan Designation: Zoning: 1.1 Project Background Trestle Rehabilitation Project City of Petaluma 11 English Street Petaluma, CA 94952 Diane Ramirez 707-776-3658 Petaluma Waterfront where Western and B Streets terminate NA City of Petaluma 11 English Street Petaluma, CA 94952 FW-Floodway FW-Floodway The Petaluma Trestle (Trestle), currently owned by Sonoma -Marin Area Rail Transit (SMART), is located on the south bank of the Petaluma River, in an area known as the "Turning Basin," in the City of Petaluma (City) (refer to Figure 1 Project Location). The original function of the Trestle was to support railroad transport and access along the Petaluma waterfront and associated shipping and goods transportation activities. Constructed in 1922, the trestle structure has sustained damage over time as a result of weathering due to the marine environment and lack of regular maintenance. The Trestle is primarily composed of wood. According to the October 2011 timber evaluation (Flynn & Associates 2011), damage to the trestle piles is extensive as a result of degradation from marine borers' within the tidal zone. The timber bracing also has extensive damage due to marine borers and rot (refer to Figure 2 Trestle Images). Because of its deteriorated condition, the Trestle has been closed to public access since approximately 2000. In 2010 the City was awarded a grant from the California Coastal Conservancy for planning and design of the trestle rehabilitation, as well as for bank stabilization and educational features. 1.2 Purpose and Need for the Proposed Action Rehabilitation of the Trestle is identified in several City planning documents as an important component of the downtown waterfront area for its historical value and for increasing riverfront uses, activities, and development. More specifically, Policy 2-P-11 of the City of Petaluma General Plan 2025, encourages the rehabilitation of the Trestle as an important part of the City's history. The purpose and need for the A marine borer is a mollusc or crustacean that lives, usually in warm seas, and destroys wood by boring into and eating it. i City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 1 proposed action is to once again have the Trestle be a safe, functional part of the Petaluma River waterfront in accordance with the following planning documents: General Plan 2025, Central Petaluma Specific Plan 2003, Petaluma River Access and Enhancement Plan 1996, and City of Petaluma Bicycle & Pedestrian Plan 2008. 1.3 Proposed Action/Project Description The City proposes to rehabilitate the existing Trestle, implement slope stabilization repairs, install educational features along the waterfront, and potentially construct a new pedestrian walkway (refer to Figure 3 Site Plan). These project components are collectively referred to as the Trestle Rehabilitation Project. Trestle Rehabilitation The Trestle, in general, is comprised of 35 bents (refer to Figure 4 Typical Bent), decking, ties, and rail tracks. Starting at the deck and moving down, a profile description of the trestle at a typical bent location is as follows: deck boards and steel rail track, deck framing, railroad ties, stringers, and bent cap supported by five piles at each bent with a sash and diagonal sway brace (refer to Figure 4 Typical Bent). There are a total of 178 Trestle piles. In addition, running the length of the Trestle are approximately 130 creosote -treated fender piles that originally served to protect the Trestle from bulk cargo barge loading and unloading operations at that location. The fender piles no longer serve any structural purpose for the trestle. A cable and post railing runs along the river side of the Trestle. The railing was installed in recent history (c1970) for safety purposes and is not part of the historic trestle (Preservation Architecture 2011). It is the intent of the City to reuse as many of the existing Trestle components as feasible. In general, components of the existing Trestle can be placed in two categories: those that could be repaired and retained as part of the rehabilitated structure, and those that are so far deteriorated that replacement is required. An exception to this is a few Trestle piles that are in good condition and do not require repair. According to an evaluation of the condition of the Trestle piles conducted in 2011, approximately 52 percent of the piles were identified as being in "poor" or "beyond poor' condition (Flynn & Associates 2011) and would therefore need to be removed and replaced. Given the existing deterioration of the Trestle, and the unknown timeframe for rehabilitation, it is not possible to precisely identify the parts that would be repaired and retained and those that would require replacement. The Trestle is in a rapid state of deterioration and it could be that as time passes the deterioration rate will increase; what may be repairable today would need to be replaced in a few years. Therefore, this project description describes several methods of construction that could occur. Table 1-1 below lists the Trestle components, the current condition of each component, and the need to repair, replace, or preserve. In some cases, the component was not fully accessible during the 2011 site investigation and therefore that component is identified as requiring further investigation before a recommendation can be provided. The steel rail track is in good condition and will be retained as part of the Project. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 2 Table 1-1: Trestle Components, Current Condition, and Planned Treatment Component Current Condition Planned Treatment Steel Rail Track Good condition Re -use Deck Boards Extensive damage Replace in-kind Deck Framing Decay damage and splitting Requires further investigation Railroad Ties Generally sound, some degradation Requires further investigation Stringers Moderate decay Repair or replace in-kind Bent Cap Generally sound with visible end splitting Repair Sway & Sash Bracing Some in sound condition, some missing or failed Combination of repair & replace in - kind Trestle Piles Fair to good to Good (approximately 2% of total) Preserve Fair to poor to Fair (approximately 46% of total) Repair Poor to Beyond Poor (approximately 52% of total) Remove and replace in-kind Fender Piles Poor to beyond poor Remove Flynn & Associates 2011 and Winzler & Kelly 2011 a Pile preservation consists of wrapping the existing pile, andPile repair consists of jacketing or wrapping of the existing piles, and, if necessary, or -replacement of damaged pile sections with new timber pile stubs. This is described in more detail under construction methods below. Repairs to bent caps or stringers will consist of hidden steel plates and fasteners or fiber reinforced polymer (FRP) wrap. A majority of the Trestle consists of creosote -treated wood components. As such, all components in contact with water to be repaired and retained in the rehabilitated structure will be coated with an epoxy or wrapped to prevent chemical leaching into the Petaluma River. Those components that cannot be preserved or repaired will be removed from the Project site in accordance with the Department of Toxic Substances Control alternative management standards for Treated Wood Waste found in California Code Regulations (CCR) title 22, division 4.5, chapter 34. For those components being replaced, the component will be replicated in design, color, texture, and where feasible, materials consistent with the original design. Potential Pedestrian Walkway The City may choose, as part of the Project, to construct a new pedestrian walkway, as shown on Figure 3 Site Plan. The pedestrian walkway could generally follow the original alignment of the historic spur that extended from the Trestle at B Street, then behind G.P. McNear Grain & Feed Warehouse, and ended at C Street. No portion of the historic spur currently exists with the exception of a few spur piles that have been broken in place and can be seen between the Trestle and the river bank. The new pedestrian walkway may consist of a concrete abutment, decking, hand rails, and piles with associated bracing. The City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 3 existing broken piles will be removed. The majority of new piles will be installed above the high tide line but some piles may be installed below the high tide line. Slope Stabilization Repairs Sloughing and slope failures along the banks of the Petaluma River adjacent to the Trestle require the placement of retaining structures for a length of approximately 50 to 75 feet to protect the Trestle and to retain adjacent landside areas. The top of the retaining structure will be installed approximately four to five feet below the top of the adjacent river bank. There are two slope repair alternatives being considered, as follows: Soldier Piles /Lagging Alternative Vertical H -piles, or similar pile structure, would be installed along with a lagging wall (refer to Figure 5 Conceptual Bank Stabilization Alternatives). Approximately 10 to 12 piles would be installed using a rotary drill. The lagging material would consist of either pressure treated timber planks, precast reinforced concrete planks or appropriately coated steel plate. Concrete planks are a preferred choice in this environment as they are the least susceptible to deterioration or corrosion over time and would require minimum maintenance. Drainage systems would be provided behind the installation to minimize hydrostatic pressures behind the wall and associated seepage through the lagging wall. Sheet Pile Alternative Under this alternative vertical sheet piles would be installed using a vibratory hammer or hydraulic, low impact "press -in" method (refer to Figure 5 Conceptual Bank Stabilization Alternatives). Sheet pile installation behind the trestle would appear more uniform in appearance than the soldier pile alternative. Sheet piles would consist of steel, vinyl or FRP material. Educational Features Educational features will be included in and around the Trestle area. The features will address such educational themes as the history of Petaluma's working waterfront, trestle and railroads, and river access and recreational opportunities. The features could be comprised of free standing graphic panels, monuments embedded in the trestle decking, structural exhibits, and/or wall -mounted displays. Construction Staging and Methods A majority of the construction will occur from the waterside utilizing a 40 -foot wide by 80- to 100 -foot long barge anchored in the Petaluma River in the area shown on Figure 3. As construction work progresses, the barge will move along the Trestle. This will provide easier and more efficient access to the work area and adequate space for the pile installation equipment. Finish work (installation of deck boards, track, hand rail, educational features, etc) will occur from the landside. As noted on Figure 3 there will be a landside staging area either to the northwest-er east of the Trestle. Trestle pile construction is separated into three categories: preserve, repair, and replace as described below. Regardless of the type of pile construction, dewatering around each pile will not be necessary. Construction Method for Preserving Trestle Piles Existing piles to be preserved will be wrapped with polyvinyl chloride (PVCJ or high density polyethylene JHDPEJ sheets extending from the mudline to mean high high water (MHHW) for size and visual consistency. The piles will be cleaned of marine growth using hydro -blasting or other mechanical means. The wraps will be placed in position on the piles by hand and secured to the piles using straps and bolts City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 4 or other fasteners. Work will be performed by workers standing in the river or from small work floats (approximately 6 feet by 6 feet). Construction Method for Repairing Trestle Piles Existing piles to be repaired will have a steel, HDPE or FRP jacket placed over the existing pile from approximately one foot below mudline to MHHW and filled with grout. If the section of the existing pile is found to be deteriorated above MHHW, a new timber pile section will be spliced using a steel pile sleeve with mechanical connections similar to the construction method for replacing piles described below. The new timber pile sections will be treated with a waterborne preservative, Ammoniacal Copper Zinc Arsenate (ACZA). The pile jackets may be installed using a small crane and work crew. Work will be performed by workers standing in the river or from small work floats. Construction Method for Replacing Trestle Piles Damaged piles to be removed and replaced will follow a tiered approach for removal. First, a vibratory hammer would be used to vibrate out the pile. If this does not work, then the pile would be broken off at or below the mudline. If this is not feasible, then the pile would be cut and removed at the mudline. If the existing, damaged timber piles can be completely removed, new timber piles will be installed. A vibratory hammer is the first choice for installation of the timber piles. If a vibratory hammer is not feasible, an-ar impact hammer will be required f„r ,ns+allati n of the timber poles. New timber piles will be treated with a waterborne preservative, ACZA as noted above. The piles will then be wrapped or coated below MHHW. If the a broken or cut pile is found to be deteriorated below the cut line, a steel pile will be driven over the "stump." An impact or vibratory hammer and crane barge will be used to install the pile. If the pile is found to be sound below mudline, a steel pile sleeve will be placed over the pile stump. The steel sleeve may be installed using a crane or with smaller equipment. A new timber pile section will then be attached to the steel pile sleeve and will support the bent cap and other trestle substructure elements. BAAQMD Basic Construction Measures As recommended by the Bay Area Air Quality Management District, the applicable Basic Construction Measures will be included in the project design and implemented during construction. Those measures include: 1) idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes; and 2) all construction equipment shall be maintained and properly tuned in accordance with manufacturer's specifications and checked by a certified visible emissions evaluator. For tracking purposes these Basic Construction Measures are included in the Mitigation and Monitoring Program for the Project, included in Appendix A. i The Basic Construction Measures also include a number of items related to dust control. As this Project does not include any ground disturbance such as grading or other soil movement, the measures related to dust control are not applicable and therefore not included in the Project. Relocation of Existing Dock The City of Petaluma owns and operates floating docks on both sides of the Turning Basin, including the one dock that runs parallel with the Trestle. An approximately 480 -foot section of the dock will need to be temporarily moved during construction (as noted on Figure 3 an approximate 125 -foot section will remain as it is located out of the construction area). The existing dock could be relocated as one piece or separated into more than one piece. There are three options for relocation. Two are on the opposite shore of the Petaluma River and the third is to place a portion of the dock on the opposite side of the City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 5 existing dock that will remain in place during construction. One or more of the areas indicated on Figure 3 would be used. Pedestrian and River Access during Construction Pedestrian access to the Balshaw Bridge will remain open during construction Access to the boat dock in front of the Trestle will be closed during construction at the western end but will remain open at the eastern end in front of the Petaluma Yacht Club as noted on Figure 3 Signs regardinq alternative access will be posted near the western access point of the dock at the entrance to the Balshaw Bridge and at other appropriate locations. Construction Schedule Construction required for rehabilitation of the Trestle is expected to last from four to five months. Construction activities can be broken into three categories: deconstruction which would last approximately 3 to 4 weeks, in -water work on the piles and bracing which would last approximately 6 to 8 weeks, and landside and finish work which would last approximately 8 to 10 weeks. Construction hours will be from 7 a.m. to 5 p.m. Monday through Friday. In -water construction work will occur from June 15 to October 30. To the extent feasible, a vibratory hammer will be used for pile installation. However, if impact hammer pile driving is necessary, it will be limited to July 1 to September 30 (CDFG 2012). Finish work could continue beyond October 30 for up to a month At this time the construction year is not known as construction funding has not yet been identified. 1.4 Surrounding Land Uses and Settings The Project is located in central Petaluma, on the south bank of the Petaluma River across from the Turning Basin. A floating dock for boat mooring and public access presently runs adjacent to the entire length of the Trestle. The Trestle is surrounded by commercial development, consisting of restaurants and shops, to the south, east and west. One of the commercial buildings to the south, and adjacent to the Proiect site, has second and third floor residential units. To the north is the Petaluma River, and beyond that is the Golden Eagle Shopping Center. Immediately to the west of the Trestle is a public promenade used for public events, and a pedestrian bridge that spans across the Petaluma River. Immediately to the east of the trestle is the Petaluma Yacht Club. 1.5 Other Public Agency Approvals U.S. Army Corps of Engineers A wetlands delineation has been verified by the Corps (refer to Appendix B Jurisdictional and Habitat Maps). A Section 10 and/or 404 Permit will be needed for fill of waters of the U.S. under the Clean Water Act. National Marine Fisheries Service (NMFS): Before granting a permit, the Corps will ask NMFS to concur with their decision to issue the permit. As federally endangered species have been identified to potentially occur near the Project site, a consultation under Section 7 of the Endangered Species Act will be required. State Historic Preservation Officer (SHPO): Before granting a permit, the Corps will ask the SHPO to concur with their decision to issue the permit. The City also must abide by the requirements of Public City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated ENIS Proposed MND 0205511002 GHD 6 i Resources Code §5097.98, Health and Safety Code §7050.5, and the Native American Graves Protection and Repatriation Act in dealing with human remains. California Department of Fish and Game A Streambed Alteration Agreement, pursuant to Section 1602 of the state Fish and Game Code, will be required. In addition, if there are affected endangered species as listed under the California Endangered Species Act, a Section 2081 Management Authorization will be required. San Francisco Bay Regional Water Quality Control Board The Board will need to issue a Section 401 water quality certification for fill of waters of state or the U.S. in support of the Section 10/404 permit. State Lands Commission A lease ffiay will be needed from the State Lands Commission. Sonoma -Marin Area Rail Transit (SMART) SMART will need to issue a Right of Entry Permit and/or a Temporary Construction Easement for construction. City of Petaluma The City will need to issue a Building Permit. 1.6 Alternatives to the Proposed Action Although CEQA does not require the analysis of alternatives in an Initial Study, an Environmental Assessment must discuss alternatives, including a No Action Alternative, as required under Section 102(2)(E) of NEPA (42 U.S.C. §4332(2)) and CEQ Regulations §1502.14(d). This section describes those aspects of the environment that could or would be affected by the Project alternatives. The Draft Conceptual Design for Rehabilitation of Petaluma Trestle (Winzler & Kelly 2011 a) included three alternatives for rehabilitation of the Trestle structure: Alternative 1 Rehabilitation (the Project, as modified herein), Alternative 2 Trestle Replacement, and Alternative 3 Complete Trestle Reconstruction. Alternative 1 is the trestle rehabilitation as described in this EA/IS (i.e.: the Project). Alternative 2 would r install new piles adjacent to the existing piles, leave the existing piles to deteriorate in place, and reuse those parts of the remaining structure that were in good condition and replace in-kind those that were not. f Alternative 3 would replace all components of the trestle with new components. All other components f(slope stabilization repairs, educational features, etc) of the project would remain the same between alternatives. The Trestle is considered eligible for the California Register of Historical Resources (this is discussed in detail in Section V Cultural Resources). Therefore a Standards Evaluation (Preservation Architecture 2012) of the three alternatives was prepared. Alternative 2 was found not to be consistent with the Standard for the Treatment of Historic Properties. Therefore, there would have been the potential that Alternative 2 would have an adverse impact on a historic resource. In addition, because Alternative 2 placed new piles alongside existing piles, impacts to waters would potentially be greater. Consequently, Alternative 2 was removed from further consideration. The Standards Evaluation did not reach a final conclusion on whether Alternative 3 was consistent with the Standards, stating that additional information regarding the design was required for a final City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 7 determination. Based on the information provided in the Draft Conceptual Design report it could not be determined if Alternative 3 would comply with Standard 3 for Reconstruction: will the project include measures to preserve any remaining historic materials, features, and spatial relationships. It was outside the scope of the Draft Conceptual Design report to identify the outcome of any remaining historic materials after dismantling of the Trestle. Therefore, Alternative 3 is considered to have a potentially greater impact on historic properties than the Project. Alternative 3 would have the same footprint as identified for Alternative 1 Rehabilitation and the construction methods would be similar to those described under Construction Method for Replacing Trestle Piles above. Therefore, in general, potential impacts, including impacts to biological resources, would be the same for Alternative 3 as for the Project. The exception to this is that Alternative 3 does not include the reuse of creosote -treated wood in the aquatic environment. Therefore, Mitigation Measure HWQ-2: Reuse of Creosote Treated Wood in Aquatic Environment would not be required for Alternative 3. The No Action Alternative examines the future without Project conditions, that is, the future if the proposed action is not implemented or constructed. This alternative would have none of the environmental impacts described in the analysis, but also would not fulfil the objectives in the Purpose and Need Statement which is to rehabilitate the Trestle for its historic and riverfront use in accordance with the City of Petaluma General Plan 2025, other City adopted planning documents. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EAMS Proposed MND 0205511002 GHD 8 I ' t7D 3JO*5 1f. rpn 1> c+4� City of Petaluma 9 y a Fara s �c. Df i a4 jrsy Alto F ; P9t):, t. 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Whilst every care has been taken to prepare this map, GHD (and DATA CUSTODIAN) make no representations or warranties about its accuracy, reliability, completeness or suitability for any particular purpose and cannot accept liability and responsibility of any kind (whether in contract, tort orotherwise), for any expenses, losses, damages andfor costs (including indirect or consequential damage) which are or may be incurred by any party as a result of the map being Inaccurate, Incomplete or unsuitable to anyway and for any reason. Data source: ESRI, Basemap; GHD, Project Site. Created bymemillarl Figure 2 Trestle Images View of decking and rails View of fender piles and bents behind fender pile City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 10 I Figure 2 Trestle Images, continued View of bent (piles, sway and sash bracing) City of Petaluma Trestle Rehabilitation Project Recirculated EMS Proposed MND GHD August2012 0205511002 11 Paper Size ANSI B N Slope Stabilization Existing Dock (to be temporarily relocated) 0 25 50 75 100 0 Staging Area Existing Trestle Feet Map Projection: Lambert Conformal Conic Barge Docking Area f Potential Pedestrian Walkway an Horizontal Datum: North AniarIf FIDS 03 7 „ Temporary Dock Relocation Options Grid: NAD 1983 StatePlane California If FIPS 0402 Feet � s ticorplwkprojectskro102055 -City ofPetaluma102055-11-002 Petaluma Trestle Rehab\06-GISXMaps1Figures1Figure 3 -Project SIm.mxd © 2012. Whilstevery care has been taken to prepare this map, GHD (and DATA CUSTODIAN) make no representations orwarmntles about its accuracy, reliability, completeness or suitability for any particular purpose and cannotaccept liability and responsibility of any kind (whether in contract, tort or ofierwise) for any expenses, losses, damages and/or costs (including Indirect or consequential damage) which are or may be incurred by any party as a result of the map being inaccurate, incomplete or unsuitable In anyway and for any reason. Data source: Plctometrv. Aerial lmaaerv. 4/1912006: GHD. Protect Features. Mav 2011. Created bvafisher2 w�� L udf c t as City of Petaluma Job Number 0205511002 Trestle Rehabilitation Revision 1 Date 27 Jul 2012 Project Site Map Figure 3 2235 Mercury Way Suite 150 Santa Rosa CA 95407 US T 707 523 1010 F 707 527 8679 E santarosa@ghd.com W www.ghd.com Paper Size ANSI B S1 City of Petaluma Job Number 10205511002 N Trestle Rehabilitation Revision 1 0 25 50 75 100 Si Date 27 Jul 2012 Feet r BI Map Projection: Lambert Conformal Conic Horizontal Datum: North American 1983 0Project Site Map Figure 3 Grid: NAD 1983 StatePlane California it FIPS 0402 Feet �, TE \\corpWkprojects\sro\02055-City ofPetaluma\02055-11-002 Petaluma Trestle Rehab\08-GIS\Maps\Fiqure\Figure 3-Pro97 US T 707 523 1010 F 707 527 8679 E santarosa@ghd.com W www.ghd.com © 2012. Whilst every care has been taken to prepare this map, G HD (and DATA CUSTODIAN) make no representations (whether in contract, tort a otherwise) for any expenses, losses, damages and/or costs (including indirect or consequential Datasource: Pictometrv. Aerial lmacerv. 4/19/2006: GHD. ProlectFeatures. May 2011. Createdbvmfisher2 (E) (3) 8"x18" STRINGERS (2) PLACES (E) 4"x8" DECK FRAMING SPACED @ 4'-0" O.C. (E) 12"x14" MIN BENT CAP SIZE VARIES 314"0 BOLT (TYPICAL) (E) 4"x8" DIAGONAL SWAY BRACE (ONE FACE OF PILE EACH) (E) (5) 12" TO 14"0 PILE (E) 4"x8" SASH (EACH FACE OF PILE) APPROXIMATE MUDLINE CITY OF PETALUMA Job Number 10205511002 PETALUMA TRESTLE REHABILITATION Revision Date APRIL 2012 PETALUMA TRESTLE TYPICAL PILE BENT ELEVATION Figure 4 2235 Mercury Way Suite 150 Santa Rasa California 95407 USA T 1 707 523 1010 F 1 707 527 8679 W w .ghd.com PW Oaf 26 Ap52p12-224 PM —R— Ns Y✓J2{155-ay MPHvmabh16S11-062 Petc+sv Tres�Rebzbm6LAD'ATneab2665116U2 FiGVPES TI •ycd-PYa6eM EYvba9 REINFORCED CONCRETE PILE CAP FILL BEHIND (N) WALL EAS TING GROUND I TOP OF PILE CAP FILTERFABMAND GRAVEL FILL B EHI N D 04 WALL STEEL, VINYL OR FRP SHEETR E 3D (PILE TIP) SHEET PILE ALTERNATIVE PROVIDE SLEEVE IN LAGGING TO ALLOIHPASSING OF UTILITIES TOP OF PILE Z— FlLL BEHIND (t1) WALL EYJSTIN. GROlF70 59"O GALVAIMO BOLT SPACED 24-O.C.�— FILTERFABRICAND -- GRAVEL FILL BEHIND(N)WALL BOTTOM OF LAGGAVG i \ CONCRETE LAGGING, TYP, SEEDS I TOP OF LAGGING BRACKET i —PRE -DRILL THROLGH (E) ROCKAS REOIP.RED SEEDETAA.2 HP 14 PILE @ 5.-B, cc 1w 1 1 ELEVATION TBD �J (PILETP) SOLDIER PILE/LAGGING ALTERNATIVE CITY OF PETALUMA Job Number 0205511002 POOR PETALUMA TRESTLE REHABILITATION Revision ' CONCEPTUAL BANK date APRIL 2012 STABILIZATION ALTERNATIVES Figure 5 2235 Mercury Way Suite 150 Santa Rosa California 95407 USA T 1 707 523 1010 F 1 707 527 8679 W vmv.ghd.Com PMN0. 26A,A-2- 4— —1.N¢ XOHf66-ef/of PelaMu'AMSSIi-062 PaL.mv TreA.a RahaE'mo CPO'6Mjaas'0205511003 FIGUpE5�4hefF5N:at Pda A0.:C�g t 2. Environmental Factors Potentially Affected The following checklist is used to evaluate the potential for significant environmental impacts/effects caused by the proposed project. All responses must consider the project in its entirety and any actions involved, including off-site as well as on-site impacts, cumulative as well as project -level impacts, indirect as well as direct impacts, and construction as well as operational impacts. This checklist is adapted from the form provided in Appendix G of the State CEQA Guidelines (as amended, 2011). The checklist is modified as appropriate for this project and to meet the requirements of the Council of Environmental Quality NEPA Regulations at 40 CFR 1500-1508. Each subject discussion includes an evaluation matrix, followed by a brief discussion explaining the evaluation rationale. The subject categories — or environmental factors — that have been considered are summarized below with the potential level of significance the proposed project may have on the environment. The levels of significance are as follows: 3 = Potentially Significant 2 = Less than Significant with Mitigation 1 = Less than Significant 0 = No Impact 1 Aesthetics 0 Agriculture Resources 1 Air Quality 2 Biological Resources 2 Cultural Resources 2 Geology & Soils 1 Greenhouse Gas Emissions 2 Hazards & Hazardous Materials 2 Hydrology & Water Quality 0 Land Use & Planning 0 Mineral Resources 2 Noise 0 Population & Housing 0 Public Services 2 Recreation 1 Transportation 1 Utilities & Service Systems 2 Mandatory Findings of Significance { City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 15 t 2.1 Determination On the basis of this initial evaluation: i 0 (� `�' 'IIs Date City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0206511002 GHD 16 I find that the proposed project/action COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION Will be prepared. I find that although the proposed project/action could have a significant effect on the X 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/action project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT Is required. I find that the proposed project/action MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 9) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. I find that although the proposed project/action could have a significant affect on the environment, because all potentially significant effects (a) have been analyzed adequately In an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, Including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required. i 0 (� `�' 'IIs Date City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0206511002 GHD 16 I. Aesthetics Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant No Impact/ Effect Would the Project: a) Have a substantial adverse effect on a X scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock X outcroppings, and historic buildings within a state scenic highway? c) Substantially degrade the existing visual character or quality of the site and its X surrounding? d) Create a new source of substantial light or glare that would adversely affect day or X nighttime views in the area? La and c) Have Substantial Adverse Effect on Scenic Vista or Substantially Degrade Visual Character or Quality of Site — Less than Significant The Trestle can be viewed by pedestrians along Water Street and Balshaw Bridge, from outdoor dining areas in the Golden Eagle Shopping Center (see Image 1 below) and Water Street, and by recreational users along the Petaluma River. In its current state the Trestle is dilapidated (see the Cover and Figure 2 in the Project Description), inaccessible, and has a chain link fence around much of the perimeter (the chain link fence is not visible in the photos herein as it was installed after the photos were taken). As part of the Project the dilapidated components of the Trestle would be replaced, repaired, or removed, and the fence would be removed, thus losing the existing "blighted" look. In addition, the rehabilitated Trestle would be of the same height and mass as the existing structure and would therefore not block views. The height of graphic panels that could be installed as part of the educational features would be low, at or below the railing. The majority of the slope stabilization improvements would be hidden between, and below, the Trestle structure and the bank of the River. Therefore, operation of the Project would not result in an adverse effect on a scenic vista or degrade the visual character of the site, and its surroundings would be improved. if the Water Street staging area is used-dUF!Rg G9RStFUGtiGR,There would be an 8 -foot high sound barrier between the staging area and the Water Street Bistro to mitigate impacts from noise during construction (this is described further in section XII Noise). The temporary barrier would block views of the Petaluma River from the outdoor dining area at the Water Street Bistro for up to five months. However, given the temporary and short-term nature of the impact the temporary effect on a scenic vista is considered less than significant. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 17 I.b) Substantially Damage Scenic Resources within State Scenic Highway — No Impact The Project is not located in, nor can it be seen from, a state scenic highway. Therefore there is no impact to scenic resources within a State Scenic Highway. I.d) Create New Source of Substantial Light or Glare — Less than Significant Most of the improvements would be constructed of wood, which is non -reflective, or would be located below the Trestle structure. Therefore, there would be no substantial reflective surfaces that would result in daytime glare. Some nighttime lighting may be added in or around the Trestle for safety purposes. Use of nighttime lighting would be consistent with the existing lighting along Water Street and other surrounding pedestrian areas, and would have assemblages that shield the light and direct it downward. The effect on nighttime views from lighting is considered less than significant. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 18 II. Agriculture and Forest Resources Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant No Impact Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the X Farmland Mapping and Monitoring Program of the California Resources Agency, to non- agricultural use? b) Conflict with existing zoning for agricultural X use, or a Williamson Act contract? c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources X Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)? d) Result in loss of forest land or conversion of X forest land to non -forest use? e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of X Farmland, to non-agricultural use or conversion of forest land to non -forest use? Il.a) Conversion of Farmland to Non -Agricultural Use — No Impact The Project site is developed and is located on the waterfront of the Petaluma River. The Project site is not mapped as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency (California Department of Conservation 2010). The Project site and surrounding waterfront land is designated as "Urban and Built -Up Land" and the Petaluma River is designated as "Other Land," which is the designation for land not included in any other mapping category, including water bodies smaller than 40 acres. Because the Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide importance to non-agricultural use, no impact would occur. II.b) Conflict with Existing Zoning for Agricultural Use or Williamson Act Contract — No Impact Maps prepared pursuant to the Williamson Act Program do not identify the Project site or vicinity as enrolled in Williamson Act contracts. The Sonoma County Williamson Act Lands 2008 map designates the Project site and vicinity as "Built-up Land" and "Incorporated City Land" (California Department of Conservation 2009). Therefore, the rehabilitation of the Petaluma Trestle would not conflict with zoning for agricultural use or a Williamson Act contract and no impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 19 Il.c & d) Conflict with Existing Zoning for Forest Land, Cause Rezoning of Forest Land or Timberland, or Result in Loss/Conversion of Forest Land — No Impact No forest land or timberland exists at the Project site. The Project site is zoned as Floodway, and is adjacent to land zoned as T-5 Urban Center. The Project would not result in the loss or conversion of forest land, or involve other changes in the existing environment which would result in conversion of forest land to non -forest use. No impact would occur. Il.e) Result in Other Changes that Could Result in the Conversion of Farmland to Non -Agricultural Use or Forestland to Non -Forest Use — No Impact The Project site is not classified as being valuable for supporting crops, livestock, forest, or timber land. No areas surrounding the Project site are mapped as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, or support forest or timber land. Neither the Project site nor the surrounding lands are used for agricultural activities. The Project would therefore not result in the conversion of farmland or forest land at the site, or indirectly in the surrounding vicinity. No impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 20 Ill. Air Quality Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project: a) Conflict with or obstruct implementation of X the applicable air quality plan? b) Violate any air quality standard or contribute substantially to an existing or projected air X quality violation? 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 X quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial X pollutant concentrations? e) Create objectionable odors affecting a X substantial number of people? The BAAQMD CEQA thresholds were recently invalidated by a trial court because BAAQMD did not itself do a CEQA evaluation of the Thresholds before their adoption. The Court, however, did not rule on or question the adequacy of the BAAQMD CEQA Air Quality Guidelines, including the impact assessment methodologies, or the evidentiary basis supporting the thresholds, which are included in the Guidelines (updated in May 2011). The City, as Lead Agency, has the discretion to use the BAAQMD CEQA Air Quality Guidelines and methodology for analyzing air quality impacts under CEQA based on the evidence and technical studies supporting the Guidelines. The following air quality analysis utilizes the impact assessment methodologies presented in the BAAQMD CEQA Air Quality Guidelines (BAAQMD 2010 and 2011). Ill.a) Conflict with or Obstruct Implementation of Applicable Air Quality Plan — No Impact Per the BAAQMD Air Quality CEQA Guidelines, the BAAQMD considers a project consistent with the Clean Air Plan if it: 1) can be concluded that a project supports the primary goals of the Plan (by showing that the project would not result in significant and unavoidable air quality impacts); 2) includes applicable control measures from the Plan, and; 3) does not disrupt or hinder implementation of any Plan control measure. The primary goals of the 2010 Clean Air Plan are to protect air quality, public health, and the climate. Because the Project would not result in a significant and unavoidable air quality impact (refer to Impacts III. b., c., and d. below), the Project would not conflict with any goals of the Plan. The Plan includes 55 Control Measures in five categories: stationary and area source; mobile source; transportation control; land use and local impact; and energy and climate. The Project does not include new stationary sources, permanent mobile sources, does not introduce a new land use, and would not use a substantial amount City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 21 of energy during operation. None of these control measures are applicable to the Project. The Project would not conflict with or obstruct the air quality plan; therefore, there would be no impact. Ill.b) Violate Air Quality Standard or Contribute Substantially to Existing Air Quality Violation — Less than Significant Project operation would not generate air emissions. There would, however be air emissions during construction from equipment and vehicle exhaust. The BAAQMD CEQA Air Quality Guidelines provide preliminary screening criteria for a lead agency to consider in making a conservative determination of a project's construction -related impacts on criteria air pollutants. The first is a land -use based screening (i.e.: residential, commercial, industrial, etc). Although the Trestle does not fall neatly into a land -use category, the Project is relatively small compared to the land -use screening sizes for listed land -use types. For example, a city park less than 67 acres or a light industrial site less than 259,000 square feet is considered to have a less than significant impact (for reference, the construction area of the Trestle Project is about 15,000 square feet). The second screening criterion is that all Basic Construction Mitigation Measures be included in the project design and implemented during construction. The applicable Basic Construction measures have been included in the Project design as noted in the Project Description. The third criterion identifies construction activities (asbestos demolition, multiple construction phases occurring at the same time, extensive site preparation, transport of over 10,000 cubic yards of soil) that would preclude a Project from a less -than -significant conclusion, none of which apply to this Project. Because of the small size of the Project, the inclusion of applicable Basic Construction Mitigation Measures in the project design, and consistency with allowed construction activities, the Project would not violate any air quality standard or contribute substantially to an existing or projected air quality violation. The impact is considered less than significant. Ill.c) Result in Cumulatively Considerable Net Increase of any Criteria Pollutant for which Project Region is non -attainment — Less than Significant According to California standards, the Bay Area Air Basin is currently designated as a nonattainment area for suspended particulate matter (PM2.5 and PM10) and ozone (BAAQMD 2012). Under national standards, the Air Basin is currently designated as marginal nonattainment for 8 -hour ozone precursors NOx, and nonattainment for PM2.5. The Air Basin is in attainment (or unclassified) for all other air pollutants with de minimis levels (U.S. EPA 2012; BAAQMD 2012). Project construction is short in duration (less than five months) and would cause limited soil disturbance. Because of the limited scope of the Project it is considered below the BAAQMD screening criteria for needing a quantitative analysis for construction and is assumed to have a less -than -significant impact from emissions of criteria air pollutants. In addition, the Project would have no operational emissions. Therefore, the Project's contribution to cumulative air quality impacts would not be considerable, and the impact would be less than significant. Ill.d) Expose Sensitive Receptors to Substantial Pollutant Concentrations — Less than Significant Operation of the Project would not emit any air contaminants. Construction of the Project would emit some air contaminants from operation of equipment and vehicles. The closest sensitive residential receptor to the Project site is the second and third floor residential units in The Lofts at Basin Street Landing that adjoin the Project site, between B Street and C Street. However, as noted under Ill.b and Ill.c above, the size of the Project is limited and construction is short. The Project would not expose sensitive receptors to substantial pollutant concentrations. No other sensitive receptors, including City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 22 i hospitals, schools, day cares, or senior facilities, are known to occur within close proximity of the Project site. w Ill.e) Create Objectionable Odors — No Impact Facilities that typically are considered to potentially create objectionable odors include such uses as wastewater treatment plants, landfills, asphalt plants, coffee roasters, and food processing. Operation of the Trestle would not emit objectionable odors nor would it create a new receptor. Therefore, there would be no impact from odors. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 23 i r IV. Biological Resources Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local X or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional X plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act X (including, but not limited to, marsh, vernal pool, etc.) through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native X resident or migratory wildlife corridors, or impede the use of native wildlife nursery site? e) Conflict with any local policies or ordinances protecting biological resources, X such as a tree preservation policy or ordinance? f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other x approved local, regional, or state habitat conservation plan? A Biological Resources Assessment (BRA) was prepared for the Project in MgL2012 and revised in July 2012 (WRA 2012). The following is based on the research, site observations, and analysis contained in the BRA (see Appendix C). The Project site is located in downtown Petaluma along the southern bank of the Petaluma River between Water Street and 1St Street and the northeastern bank across the river, and consists of a historic railroad trestle and adjacent riverbanks. Beneath the Trestle is open water and/or mudflat, and on the eastern portion of the river bank a fringe of salt/brackish marsh vegetation is present. Landscaped grass and City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 24 ornamental shrubs occupy the upper bank in open areas. Inland from the Trestle and river bank, dense urban development, parking areas, and roads are present. Elevations of the Project site range from approximately 0-10 feet above sea level. The Petaluma River is a tidal slough connected to San Pablo Bay 16 miles to the south. The main slough channel passes through the extensive Petaluma Marsh Wildlife Area, the largest remaining natural tidal brackish marsh in California. The Petaluma River is dredged regularly to maintain shipping access. Table IV -1 lists the acreage of each biological community type observed in the Project area. Non - sensitive biological communities in the Project area include ruderal habitat and ornamental vegetation. The two sensitive biological communities found in the Project area include coastal brackish marsh and waters. Descriptions of each biological community are given below. The Biological Habitat Communities map in Appendix B shows the extent of coastal brackish marsh and waters. Table IV -1: Biological Communities within Project Area Community Type Area (acres) Ruderal 0.37 Ornamental 0.35 Coastal Brackish Marsh 0.36 Waters 5.00 Total Biological Communities 6.08 Non -sensitive Biological Communities Non -sensitive biological communities are those communities that are not afforded special protection under CEQA, or other state, federal, and local laws, regulations and ordinances. These communities may, however, provide suitable habitat for special -status plant or wildlife species as identified or described below. The margins of the Project site above the high tide line support areas of landscaped ornamental vegetation and unmaintained areas of non-native plants typically considered to be ruderal habitat. Ruderal Habitat Although not described in the literature as a habitat type, ruderal habitat includes areas that have been partially developed and left fallow or otherwise have had past soil disturbance but is not necessarily currently used or maintained. The Project site supports approximately 0.37 acres of this habitat which is comprised of disturbed riverfront habitat fragments, and some adjoining ornamental vegetation alongside parking lots or businesses. Plant species often observed in ruderal habitat include wild oat (Avena sp.), black mustard (Brassica nigra), chicory (Chicorium intybus), bull thistle (Cirsium vulgare), bindweed (Convolvulus arvensis), horseweed (Conyza canadensis), fennel (Foeniculum vulgare), common tarweed (Centromadia pungens), prickly lettuce (Lactuca serriola), and bur clover (Medicago polymorpha). Ornamental Landscaped/ornamental trees, shrubs and grasses occupy approximately 0.35 acres of the Project site. Ornamental vegetation is not a community described in the literature as a habitat type, but in the Project area it includes planted native trees, such as coast redwood (Sequoia sempervirons) and deer grass City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 25 (Muhlenbergia rigens). Ornamental trees, shrubs, or dense grass can provide nesting and foraging habitat for some wildlife. Sensitive Biological Communities Sensitive biological communities include habitats that fulfill special functions or have special values, such as wetlands, streams, and riparian habitat. These habitats are regulated under federal regulations (such as the Clean Water Act), state regulations (such as the Porter -Cologne Act and the California State Fish and Game Code), or local ordinances or policies (City or County Tree Ordinances, Special Habitat Management Areas, and General Plan Elements). Two sensitive biological communities were observed within the Project area: coastal brackish marsh and waters (the Petaluma River). Beneath the Trestle is open water with areas of mudflat exposed at various stages of low tide. Coastal brackish marsh occurs in sparse patches on the river bank alongside the Trestle and on the eastern riverbank. These habitats are described in more detail below. Waters The Petaluma River flows through the Project area and is considered an "Other Waters" under the jurisdiction of the U.S. Army Corps of Engineers (Section 404 Clean Water Act up to high tide line and Section 10 Rivers and Harbors Act up to mean high water). Approximately 5.00 acres of other waters were observed in the Project area. The Petaluma River has been documented supporting special -status wildlife species. It is considered Critical Habitat for Steelhead - Central California Coast Evolutionarily Significant Habitat (ESU)(Oncorhynchus mykiss irideus), a federal threatened species. The Petaluma River also has the potential to support Chinook Salmon (Oncorhynchus tshawytscha) in the Project area. Coastal Brackish Marsh Coastal brackish marsh is found at the interior edges of coastal bays and estuaries and is often adjacent to Salt Marsh, another sensitive habitat type. The Coastal brackish marsh supports some plants in common with salt marsh, but generally has lower salt concentration than salt marsh because of freshwater input; and salinity may vary considerably with tide or season. In the Project area marsh vegetation is sparse and consists mainly of saltmarsh bulrush (Bolboschoenus maritimus) and California tule (Schoenoplectus californicus). Other plant species include marsh gumplant (Grindelia stricta), pickleweed (Sarcocomia virginica), and salt grass (Distchlis spicata). Special -Status Species Special -status plant species include those species that have been formally listed, are proposed as endangered or threatened, or are candidates for such listing under the federal Endangered Species Act (ESA) or California Endangered Species Act (CESA). These Acts afford protection to both listed and proposed species. Plant species on California Native Plant Society (CNPS) Lists 1 and 2 are also considered special status plant species, and impacts to these species are considered significant according to CEQA. CNPS List 3 plants are not required to be reviewed under CEQA, but are included in this analysis for completeness. Special -status wildlife species include those species that have been formally listed, are proposed as endangered or threatened, or are candidates for such listing under the federal Endangered Species Act (ESA) or California Endangered Species Act (CESA). Special -status wildlife species also includes California Department of Fish and Game (CDFG) Species of Special Concern, U.S. Fish and Wildlife City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 26 Service (USFWS) Birds of Conservation Concern, sensitive species included in USFWS Recovery Plans, and CDFG special status invertebrates. Although CDFG Species of Special Concern generally have no special legal status, they are given special consideration under the California Environmental Quality Act (CEQA). In addition to regulations for special -status species, most birds in the United States, including non -status species, are protected by the Migratory Bird Treaty Act of 1918. Destroying active nests, eggs, and young is illegal under this legislation. Plants Thirty special -status plant species have been documented in the vicinity of the Project area; however, none of these species are likely to be present at the Project site (WRA 2012). The vegetated area consists of three communities, two of which typically do not support special -status plant species because r they are previously disturbed and are either extensively managed and maintained (landscape/ornamental) or are dominated by non-native weeds that out compete native plants (ruderal). The third community, coastal brackish marsh, is a fringe along the steep river bank dominated by tall tulles. This habitat is not suitable for special -status tidal plants. No special -status plants were observed during the 2012 survey. Appendix C summarizes the special status plant species that have been documented in the vicinity of the Project area and their potential for occurrence (identified as either not present or unlikely to occur). Fish and Wildlife Fifty-eight special -status species of wildlife have been documented in the vicinity of the Project area (CDFG 2011, USFWS 2011). All, except two, are considered to either not be present at the Project site or unlikely to be present due to lack of suitable habitat and surrounding urban development (summarized in more detail in Appendix C Biological Resource Assessment). No special -status wildlife species were observed at the Project site during site visits. Two special -status fish species are known to be present in the Project area, Steelhead and Chinook salmon, and are discussed in more detail below. Discussions on preen sturgeon, longfin smelt, and bats have also been included in response to comments received during circulation of the June 2012 EA/IS. Green sturgeon and bats are still considered as unlikely to be present at the Project site, while longfin smelt is conservatively identified as potentially occurring in the Project area during certain times of the year. Steelhead - Central California Coast ESU (Oncorhynchus mykiss irideus), Federal Threatened Species: The Central California Coast ESU includes all naturally spawned populations of steelhead (and their progeny) in California streams from the Russian River to Aptos Creek, and the drainages of San Francisco and San Pablo bays eastward to the Napa River (inclusive), excluding the Sacramento -San Joaquin River Basin. Steelhead typically migrate to marine waters after spending two years in freshwater, though they may stay up to seven years. They then reside in marine waters for 2 or 3 years prior to returning to their natal stream to spawn as 4 -or 5 -year-olds. Steelhead adults spawn between December and June. In California, females typically spawn twice before they die. Preferred spawning habitat for steelhead is in perennial streams with cool to cold water temperatures, high dissolved oxygen levels and fast -flowing water. Abundant riffle areas (shallow areas with gravel or cobble substrate) for spawning and deeper pools with sufficient riparian cover for rearing are necessary for successful breeding. 2 No published documentation could be found that longfin smelt are present in the Petaluma River above the confluence with San Antonio Creek. CDFG reported in a letter to the City of Petaluma that recent surveys indicated the presence of this fish in the Petaluma River. However, in subsequent discussions it was found that the surveys were performed in the late 1990's in San Antonio Creek, a downstream tributary to the Petaluma River. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 27 Central California Coast steelhead migrate up the Petaluma River in the fall and winter to spawn in the winter and spring. Although the Project site does not provide suitable gravel substrate for spawning, adults of this ESU likely migrate through in search of spawning habitat, and juveniles may find suitable protective cover and foraging habitat in the Project area. The Petaluma River is considered Critical Habitat for this ESU by the National Marine Fisheries Service (NMFS), and California Natural Diversity Database (CNDDB) records indicate that this ESU has been observed in the Petaluma River system within five miles of the Project site. Therefore, the Project area represents migration and potentially rearing habitat for this species. Chinook Salmon - Central Valley Fall/late fall-run ESU (Oncorhynchus tshawytscha) NMFS Species of Concern, CDFG Species of Special Concern: The Central Valley fall/late fall-run ESU includes all naturally spawned fall-run populations from the Sacramento - San Joaquin River mainstem and its tributaries. Late-fall run Chinook salmon are morphologically similar to spring-run Chinook. They are large salmonids, reaching 75-100 cm SL and weighing up to 9-10 kg or more. The great majority of late- fall Chinook salmon appear to spawn in the mainstream of the Sacramento River, which they enter from October through February. Spawning occurs in January, February and March, although it may extend into April in some years. Fry have emerged by early June, and the juveniles hold in the river for nearly a year before moving out to sea the following December through March. The specific habitat requirements of late-fall Chinook runs have not been determined, but they are presumably similar to habitat requirements for other Chinook salmon runs, and fall within the range of physical and chemical characteristics of the Sacramento River above Red Bluff. Following winter rains, this species may migrate through the Project area in search of appropriate spawning habitat. In the Project area, no gravelly substrate characteristic of Chinook spawning habitat is available; however, the aquatic habitat in the Project area may provide suitable rearing and foraging habitat for juveniles. Although the Petaluma River is outside the currently established range of this species, this ESU has been observed there (pers. comm., Amanda Morrison, NMFS). Longfin Smelt (Spirinchus thaleichthys), Federal Bay-Delta DPS Candidate State Threatened: U.S. Fish and Wildlife Service has listed the Bay-Delta distinct population segment of longfin smelt as a candidate endangered or threatened species (other longfin smelt populations have not been listed) in a 12-month finding announced in March 2012. Longfin smelt are considered pelagic and anadromous spawning in freshwater and moving into estuarine and ocean waters as they mature with the suitable salinity range between 14 to 28 parts per thousand (ppt). They do not tolerate water temperatures higher than 22 degrees Celsius (72 degrees F) and typically move seaward to San Francisco Bay and cooler water during the summer. Spawning typically occurs between January and April but may begin as early as November and be as late as June, and occurs over sandy substrate. This fish is documented to occur throughout San Francisco Bay and the Delta region No published documentation could be found that longfin smelt are present in the Petaluma River above the confluence with San Antonio Creek. While longfin smelt may be in the Petaluma River and within the Project area during portions of the year, it is unlikely they are in the upper Petaluma River and the Project area during the summer when water temperatures reach intolerable level. Water temperatures at the Project Area (Petaluma River Turning Basin) were measured to be 22.9 degrees Celsius (73.2 degrees F) in late May of 2004 (Cohen et. al. 2005). CDFG has determined an acceptable work window for protection of longfin smelt, should they be present, to be between July 1 and September 30. Green Sturgeon (Acioenser medirostris), Federal Threatened Southern DPS CDFG Species of Special Concern: Green sturgeon is a large (to 7 feet) anadromous fish present in coastal waters along the west City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 28 coast. Adults spawn every two to five years returning to upper reaches of freshwater streams with deep turbulent waters in late February with peak activity from April to June. Critical Habitat designation has been proposed but not finalized, and the designation includes tidal areas of the Petaluma River. However, available data indicate that green sturgeon have not actually been observed upstream of the mouth of the Petaluma River at San Pablo Bay. NMFS concluded in a Biological Opinion (NOAA 2009) for Caltrans bridge construction work at several locations along the Petaluma River that green sturgeon were unlikely to be present in the reach between the Highway 101 bridge and Washington Street bridge. Because the Project is located within this reach, green sturgeon are considered to be unlikely at the Project site. Bats (Pallid Bat (Antrozous pallidus), Townsend's Big -eared Bat (CorMorhinus townsendii), Western Red Bat (Lasiurus blossevillii)), Species of Special Concern: All of these bats are considered unlikely to be present in the Project area based on records occurrences that indicate the nearest bat occurrence was more than a mile away and due to proximity to human activity in the downtown area. During circulation of the June 2012 EA/IS California State Lands Commission indicated that non-use of the fenced -off trestle could potentially attract bats, and out of an abundance of caution this is discussed here. Bats typically hibernate between the months of November and March and are active between April and October for breeding and foraging. Day roosts are occupied during the day when not foraging and night roosts are places for bats to rest between periods of foraging. Hibernating habitat requires conditions where there is no disturbance and low temperatures are maintained between 1 degree Celsius (33.8 degrees F) and 12 degrees Celsius (53.5 degrees F) so that bats can enter a period of reduced metabolic activity (torpor) to conserve energy. Temperatures below freezing can be lethal, and warmer temperatures may cause bats to become active at the wrong time of year and risk starvation. Maternity sites are sensitive to disturbance and need to have conditions where relatively high temperatures are reached and space is large enough for several females and young. They typically include a cavity or "heat trap" where temperatures are maintained between 30 degrees Celsius (86 degrees F) and 40 degrees Celsius (104 degrees F). IV.a) Have Substantial Adverse Effect on Candidate, Sensitive, or Special -Status Species — Less than Significant with Mitigation No special -status plants were observed during the 2012 site visit. In addition, because the vegetated area is relatively small and is in an isolated, urban location, the Project site likely does not support any of these species. Bats are unlikely to be present within the Project area. Because of the openness of the trestle structure, it is not likely that conditions are appropriate for either hibernation or maternity habitat. Air circulation through the structure in winter could reduce temperatures to below freezing at times or above 12 degrees Celsius (53.6 degrees Fahrenheit) during warm days in winter. Similarly for maternity habitat, air circulation through the structure does not allow conditions where high temperatures are maintained even if spaces for rearing are present. Two special -status fish species have the potential to occur in the Project area: Central California Coast Steelhead and Central Valley fall/late fall -run Chinook salmon ESU. Although the Project area does not provide spawning habitat, the species could pass through the Project area during migration. Although conditions at the Project site are unfavorable for longfin smelt, as noted in the setting description above, a third special -status fish species, longfin smelt, is conservatively assumed to be present in the Project area from October 1St to June 30tH City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 29 Project construction would include pile installation, includinq Trestle piles, pedestrian walkway piles and slope stabilization sheet piles, within the Petaluma River, where the three potentially present special status fish species could occur. When a pile driving hammer strikes a pile, a pulse is created that propagates through the pile and radiates sound in the water, the ground, and the air. The total sound energy in an impulse accumulates over the duration of that pulse. How rapidly the energy accumulates may be significant in assessing the potential effect if impulses on fish. On June 12, 2008, NOAA's National Marine Fisheries Service (NMFS), U.S. Fish and Wildlife Service, California, Oregon, and Washington Departments of Transportation, California Department of Fish and Game and the U.S. Federal Highway Administration agreed in principal to interim criteria to protect fish from pile driving activities (Illingworth & Rodkin 2012c). The criteria are based on a peak single strike and a cumulative sound exposure level (SEL) over a day of pile driving. The accumulated level is reset after a 12 -hour recovery period without impact driving. Where underwater pile driving noise exceeds a peak of 206 dB or cumulatively exceeds 183 dB SEL for fishes less than 2 grams or 187 dB SEL for fishes greater than or equal to 2 grams, it would exceed the criteria, and potentially harm fish. Impact hammer pile driving of Trestle wood piles is expected to generate peak noise levels between 170 and 180 dB, based on measurements taken at construction sites with similar construction methods as the Trestle Project (Illingworth & Rodkin 2012b). Although estimated to be below the peak noise criterion, pile driving could still exceed the cumulative SEL criterion. In addition, pile installation could cause disturbance of bottom sediment and increased turbidity and construction debris or fuels could inadvertently enter the water. Upland habitat at the Project site is ruderal, fragmented, and partly ornamental, with some trees shrubs and grasses providing low -quality nesting habitat for migratory birds. If nests are present Project construction could disturb nesting activities. Impacts to special -status wildlife species during construction would be significant without mitigation. Mitigation Measure BRA: Protect Longfin Smelt, Central California Coast Steelhead, and Chinook Salmon If an impact hammer is used, pile driving shall be limited to the period of July 1 to September 30th -no '. 5 +n (ln+nhor '.2'I ni +oir7o of the mind++inn norinrl Pile driving methodology and schedulinq shall be reviewed by the National Marine Fisheries Service and Department of Fish & Game. If the work window is not sufficient to complete pile driving, a longer work window is acceptable if allowed by the National Marine Fisheries Service and Department of Fish & Game. Project work other than pile driving may continue before, during, or after the final approved work window that allows impact hammer pile driving. This mitigation measure does not apply to the use of a vibratory hammer. Mitigation Measure BR -2: Protect Birds If construction activities cannot be avoided during the nesting season (February through August) pre -construction surveys for active nests shall be conducted by a qualified biologist within 15 days prior to start of work. The results of the survey shall be recorded and made available to CDFG and U.S. Fish & Wildlife Service upon request. If an active nest is found, the biologist shall consult with CDFG and USFWS regarding appropriate action to comply with the Migratory Bird Treaty Act of 1918 and the Fish and Game Code. Mitigation Measure HWQ-1: Water Quality Construction Measures Described in Section IX Hydrology and Water Quality. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 30 Implementation of Mitigation Measure HWQ-1 will contain turbidity, prohibit discharge of construction materials to the Petaluma River, and provide containment or clean-up in the event of accidental discharge. Refer to Section IX Hydrology and Water Quality with regard to the re -use of creosote treated piles in the aquatic environment and the impact on water quality. Therefore, because the implementation of Mitigation Measures BR -1, BR -2, and HWQ-1 will reduce potential impacts to longfin smelt, Central California Coast steelhead and Chinook salmon, and birds, including construction noise impacts and potential impacts from sediment disturbance, increased turbidity and inadvertent discharge of construction debris or fuels, impacts to candidate, sensitive or special -status species would be less than significant with mitigation. During circulation of the June 2012 EA/IS a comment letter was received asking that the potential for the Project to introduce invasive species be analyzed. Introduction of invasive species can be in the form of live organisms or propagules often carried in on vehicles, on construction equipment, in discharged ship ballast, or other means in sufficient numbers and timing such that they are capable of colonization and reproduction. The comment letter specifically pointed out the quagga mussel, which has been spreading across the United States after being introduced into the Great Lakes by ship ballast water from Europe. In the case of the quagga mussel, for example, the high salinity of the Petaluma River during the low flow period in summer would not allow this invasive mussel to become established. The quagga mussel can tolerate water salinity no higher than 4-5 parts per thousand (Benson, Richerson, Maynard, Larson, and Fusaro 2012). In summer the entire tidally influenced reach of the Petaluma River reaches 10 ppt salinity and higher (City of Petaluma 2002) and Cohen et. al. measured water salinity in the Project area (Petaluma River Turning Basin) in late May 2004 to be 8 ppt. Therefore, even if introduced into the Petaluma River at the Project site, quagga mussels would succumb to intolerable salinity. In addition, the relatively small size of the Project is likely to only attract local contractors (around San Francisco Bay) that are not likely to be carrying new invasive species from distant locations that are not already established in the Petaluma River. New introductions of invasive vascular plants into the Project area are not likely because of the relatively small area of high intertidal and uplands capable of being occupied by plants. The plant community presently is a mixture of native and non-native plants with dense cover, and establishment by a new species is unlikely. Areas temporarily disturbed during construction would likely be quickly re -colonized by re -growth of the plant species that are now present and/or by native plants installed for revegetation. The Project would not cause a significant impact by introducing invasive species. IV.b) Have Substantial Adverse Effect on any Riparian Habitat or other Sensitive Natural Community - Less than Significant with Mitigation No riparian habitat is present at the Project site. There is approximately 0.36 acre of coastal brackish marsh within the Project area. Temporary disturbance could occur during relocation/anchoring of the floating dock, and during construction in the area of the slope stabilization improvements and the pedestrian walkway. Permanent impacts to coastal brackish marsh of up to 0.03 acre would result from the piles and lagging wall installed as part of the soil stabilization improvements and, if installed, from shading and pile installed for the pedestrian walkway (refer to Appendix B Jurisdictional and Habitat Maps). Mitigation Measure BR -23: Protect Coastal Brackish Marsh Temporary impacts during construction shall be limited to the smallest area possible, with the limit of disturbance marked on the construction documents. Where practical, protective materials, City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 31 such as geotextile fabric, will be laid down for the temporary placement of excess excavated soil or other materials, and plywood will be used to create walkways for construction workers, to protect vegetation around the work area. During construction best management practices to prevent sediment runoff shall be implemented. A qualified biologist shall be onsite to monitor initial project work, to ensure proper implementation of the best management practices, and to provide a training session to the work crew on the importance of following mitigation measures in order to avoid impacts to sensitive habitat and special -status species. The biologist shall make periodic site visits to inspect work practices. All areas temporarily disturbed during construction shall be repaired after work is completed, including: 1. Remove excess excavated soil; 2. Remove protective materials; and 3. Replant vegetation with native species appropriate to coastal brackish marsh habitat. Coastal brackish marsh habitat that is lost as a result of the placement of permanent fill shall be replaced by expanding coastal brackish habitat at a suitable nearby location, such as the McNear Peninsula Park approximately 1,500 feet downstream, at no less than 1:1 ratio. A mitigation plan shall be prepared by a qualified biologist identifying the location, implementation (including a planting plan), and monitoring of the expanded coastal brackish marsh habitat. The plan shall include performance criteria for establishment of brackish marsh plants that, at a minimum require 80 percent of cover with species similar to a nearby brackish marsh reference site, after five years. Implementation of Mitigation Measure BR -23 will require the use of best management practices to ensure that temporary disturbance to coastal brackish marsh during construction is minimized. Mitigation Measure BR-23also will require that any coastal brackish marsh habitat that is permanently lost as a result of the Project be replaced at a minimum 1:1 ratio. A suggested site to implement the replacement mitigation is McNear Peninsula Park for which the City Council adopted a Mitigated Negative Declaration in 2003 (City of Petaluma 2003). The McNear Peninsula Park project includes a restoration component and has adequate space to integrate the required mitigation. Project impacts to sensitive natural communities (i.e., coastal brackish marsh) would be less than significant with mitigation. IV.c) Have Substantial Adverse Effect on Federally Protected Wetlands - Less than Significant The Petaluma River is considered a Waters of the U.S. under Section 404. Repair of the Trestle structure would increase fill in the Petaluma River by approximately 200 square feet, from pile repair and replacement, as described in the Project Description. The existing piles are approximately 14 inches, while the new and repaired piles would be 20 inches in diameter. In addition, some of the new supporting piles for the pedestrian walkway may be installed below the high tide line (Waters of the U.S. at and below the high tide line is considered within Section 404 Corps jurisdiction). At the location of the Trestle, the Petaluma River is approximately 150 feet wide, with the Trestle width covering approximately 18 feet. The addition of 200 square feet of fill, isolated within the area of the existing Trestle adjacent to the river bank (shown on Figure 3 in the Project Description), is considered insignificant in comparison to the amount of river bottom area in the Petaluma River. Therefore, the impact to federally protected wetlands is considered less than significant. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 32 IVA) Interfere Substantially with Movement of Native Resident or Migratory Fish or Wildlife Species or Migratory Wildlife Corridors, or Impede use of Native Wildlife Nursery Site — Less than Significant with Mitigation The Petaluma River is used by Central California Coast steelhead and Chinook salmon and potentially longfin smelt, to migrate to their respective spawning habitat. Noise created during installation of the Trestle piles could disrupt their migration. Impact from construction noise on the migration of the steelhead and salmon is considered significant. F - Mitigation Measure BR -1: Protect Longfin Smelt, Central California Coast Steelhead and G. Chinook Salmon Protection Mitigation Measure BR -1 will disallow pile driving within the river during the migration and spawning j period of the steelhead and Chinook salmon. Therefore, impacts to the movement of fish or wildlife species or wildlife corridors would be less than significant with mitigation. There are no native wildlife nursery sites within or near the Project site; no impacts would occur to native wildlife nursery sites. IV.e) Conflict with Local Policies or Ordinances Protecting Biological Resources — No Impact Policies 4-P-1, 4-P-2, and 4-P-3 of the Petaluma General Plan 2025 (City of Petaluma 2008a) address protecting and enhancing the Petaluma River, and special -status species and habitat within Petaluma. The Programs identified to implement the policies include maintaining public access to the Petaluma River, prioritizing potential impacts by first avoiding, then providing on-site mitigation, and then off-site mitigation, and preparation of site-specific biological resource assessments to identify impacts. Implementation of the Project is in support of these Programs. Implementation of the Project would restore a portion of the River to pedestrian access overlooking the River. A site-specific biological resource assessment has been prepared and includes mitigation for impacts to wetlands and special - status species and habitat. The Project would not be in conflict with Chapter 17 Tree Preservation of the City's Code as no protected trees would be removed as part of the Project. The Project would not conflict with local policies or ordinances protecting biological resources. Therefore, because the Project would be consistent with the Petaluma General Plan 2025 policies and programs, would mitigate impacts to wetlands and special -status species and habitats (through Mitigation Measures BRA, BR -2, BR -3 and HWQ-1), and because no protected trees would be removed, there would not be a conflict with local policies and ordinances. IV.f) Conflict with Provisions of Adopted Habitat Conservation Plan or Natural Community Conservation Plan — No Impact There are no adopted habitat conservation plans or natural community conservation plans for the Project site. No impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 33 V. Cultural Resources Potentially Significant Impact/Effect Less than Significant With Mitigation Less than Significant No Impact Would the project: a) Cause a substantial adverse change in the significance of historical resources as defined X in CEQA §15064.5? b) Cause a substantial adverse change in the significance of an archeological resource X pursuant to CEQA §15064.5? c) Directly or indirectly destroy a unique paleontological resource or site, or unique X geologic feature? d) Disturb any human remains, including those X interred outside of formal cemeteries? NEPA regulations require a federal agency to identify historic properties within a project's ("undertaking's") area of potential effects (APE), assess any adverse effects, and resolve the adverse effects. Historic property is defined as any prehistoric, or historic district, site, building, structure, or object included in or eligible for inclusion in the National Register of Historic Places (National Register) maintained by the Secretary of the Interior. The term includes properties of traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization and that meet the National Register criteria. This process must be conducted in consultation with the State Historic Preservation Officer (SHPO), and any "Indian tribe or Native Hawaiian organization that attaches religious and cultural significance to historic properties that may be effected by an undertaking." (36 CFR 800.2). Under State CEQA Guidelines 15064.5, the CEQA Lead Agency, which is the City of Petaluma for the Project, must identify any historical resources that could be affected by the Project, determine the effect of the project on identified resources, identify feasible measures to avoid or mitigate those impacts to a less than significant level, and ensure that adopted measures are fully enforceable. Historical resource is defined as any resource listed in or determined to be eligible for listing in the California Register of Historical Resources (California Register). In addition, resources included in a local register of historical resources or identified as significant in a cultural resources survey shall be presumed to be historical resources. Any archaeological resource that does not qualify as an historical resource, but that meets the definition of "unique archaeological resource" per CEQA Public Resource Code (PRC) 21083.2(g), receives similar protections to those afforded to historical resources. Area of Potential Effects The first step in the resource identification process under 36 CFR Part 800 is to determine and document an undertaking's APE. The APE means the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist. Determining the APE also contributes to the cultural resources review required under CEQA. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 34 The APE for the proposed project is located in central Petaluma along the south bank of the Petaluma River, as shown in Figure 3. The APE consists of all areas that may be affected by the project. These include the existing Trestle; the existing Petaluma Yacht Club boat dock and proposed temporary dock relocation sites; the railroad spur, which is the proposed location of a new pedestrian walkway; the location of slope stabilization repairs; the locations along the waterfront where educational features would be installed; and the —three temporary construction staging areas. Because the trestle is a major contributor to the historic feel of the riverfront, the APE also includes the riverfront and the adjacent buildings within Petaluma Commercial Historic District. Inventory of Historic Properties and Historical Resources A record search was conducted at the Northwest Information Center (NWIC) of the California Historical Resources Information System in November 2011 to identify any previous cultural resources studies that may have been conducted within and near the APE; and to identify any known prehistoric and historic archaeological resources, and historic period resources of the built environment (buildings, structures, and objects) within and near the APE (NWIC File No: 11-0375). The NWIC is the official State repository for records and reports on prehistoric and historic archaeological resources, and for the historic built environment in Sonoma County. The record search consisted of an examination of the following documents: f,0 NWIC base maps (USGS 7.5 -minute topographic maps) to identify recorded archaeological sites and recorded historic period resources of the built environment, and any cultural resources studies previously undertaken within a % mile radius of the APE. • The California Department of Parks and Recreation's California Inventory of Historic Resources (1976) and the Office of Historic Preservation's Historic Properties Directory (HPD, updated 15 March 2011), and Archaeological Determinations of Eligibility list to identify California Historical Landmarks, California Points of Historic Interest, and California historic properties that are listed 4 in or determined eligible for listing in the NRHP or the CRHR. • The Caltrans Bridge Inventory to identify any historically significant bridges. • Historic -period maps, including the 1867 A.B. Bowers Map of Sonoma County, 1877 Thos. H. Thompson & Co. Historical Atlas Map of Sonoma County, 1888 Bell & Heymans Map of Sonoma County, 1908 McIntire & Lewis Official Map of the County of Sonoma, the 1914 USGS Petaluma Quadrangle, and the 1864 General Land Office Plat Map for TSN, R7W. In addition, to assist in the identification of cultural resources, letters were sent to the Native American Heritage Commission (NAHC) (Davis 2011) and to five Native American groups/individuals that may attach religious and cultural significance to cultural resources that may be effected by the Project. The NAHC responded that the record search of the Sacred Lands File did not indicate the presence of Native American cultural resources in the immediate project area (Sanchez 2011). A letter response from Nick Tipon, Federated Indians of Graton Rancheria, Sacred Site Protection Committee, states that due to the limited scope of soil disturbance involved in the project, the Tribe has no formal recommendations or concerns at this time (Tipon 2011). The record search found that extensive cultural resources studies have been previously undertaken within the APE and surrounding areas. A total of 51 cultural resources studies were conducted between 1977 and 2011, that included archaeological field surveys, historic studies, regional overviews, architectural surveys, archaeological monitoring and excavations, and historic structure evaluations. These studies resulted in the recordation of 15 cultural resources that include historic residential, industrial and commercial buildings/structures; and historic archaeological resources. In addition, the Petaluma Historic City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 35 Commercial District is located immediately adjacent to the APE. The District encompasses an area bounded by Prospect Street to the north, "D" Street to the south, the Petaluma River to the east, and Kentucky and Fourth streets to the west. With the exception of several blocks southeast of Second and "B" streets, the district is also a National Register district, listed on the National Register in 1995. No prehistoric archaeological resources have been recorded within or near the APE. Five of the above studies encompassed the APE for this project. A preliminary Evaluation for Cultural Resources Along Water Street in Petaluma (Chattan 2002) included a records search and surface reconnaissance of the area along Water Street from Western Avenue north of Washington Street, and adjacent to the west bank of the Petaluma River. This study included the proposed project's staging area along Water Street. An Evaluation of Cultural Resources along the Proposed Petaluma Trolley Master Plan Project, Petaluma, Sonoma County (Chattan 2003a) included a records search and surface reconnaissance of approximately three linear miles along the right-of-way of the Petaluma and Santa Rosa Railroad and within portions of the historic district. This study covered the locations of all the proposed project elements along the south bank of the river, including the slope stabilization area, existing trestle and dock, and twe e# the staging areas. A Preliminary Evaluation for Cultural Resources along the Proposed Petaluma River Walk, Petaluma, Sonoma County (Chattan 2003b) included a records search and a 1.5 mile long surface reconnaissance along both sides of Petaluma River between Lynch Creek and the D Street Bridge. This study covered the locations of the proposed project elements along the south bank of the river, including the slope stabilization area, and existing trestle and dock. An Archaeological Evaluation of the Proposed Petaluma Town Center Project, Petaluma, Sonoma County, California (Roop 2003) included the proposed eastern staging area at the end of First Street. Although these four studies did not identify any archaeological resources within the APE for the proposed project, they all agree that although there is a low potential for the presence of prehistoric archaeological resources, the potential for encountering buried historic archaeological resources is high. Not only is the trestle itself historically significant, but the trestle site is the location where the earliest shipping traffic docked in Petaluma. Remnants of the original wharf piles, as well as the original timber retaining wall system are visible at low tide. The types of resources likely to be present below surface in and around the APE include historic trash deposits within the soil underneath Water Street, buried foundations or wooden piers in the soil surrounding the Turning Basin, and historic deposits including bottles, ceramics along the banks of the Petaluma River between Washington Street and D Street. In addition, a search of the California State Lands Commission Shipwrecks Database indicates that the remnants of five sunken maritime vessels are potentially within the Project area. Between the years 1855 and 1920, these vessels, including the Pilot, Georgia (or Geor is iana), Petaluma #2, Gold, and Agnes Jones, sank as a result of explosions or fires. Therefore, remnants of the vessels, vessel parts, or cargo may still be present within the river (Oggins 2012). from fill or from sunken ship The Chattan 2003a report states that the trestle is a major visual contributor to the historic feel of the riverfront and that if it is repaired according to the Secretary of the Interior's guidelines for historic structures, the trestle could be eligible as a contributor to the historic district. The Chattan 2002 and 2003b reports state that the P&SR railroad tracks along Water Street also appear to be eligible as a contributor to the historic district. The fifth study, A Cultural Resources Evaluation of the Petaluma Trestle Renovation Alternatives, on the Petaluma River, Petaluma, Sonoma County California (Chattan 2004), evaluated potential impacts to archaeological resources from the placement of new or remodeled portions of the existing trestle. Similar City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 36 to the above three studies, this study concludes that historic debris is likely to be present in the vicinity of the trestle. The report recommends that when earth -disturbing work is to occur beneath and adjacent to the trestle, an archaeologist should be involved to recover historic artifacts. The report further recommends that the trestle along with the wooden piers from older wharfs and the remains of spur tracks should be officially recorded on State DPR 523 forms. In addition to the above studies on file at the NWIC, the City of Petaluma, Department of Public Works retained PAST Consultants and Creegan + D'Angelo Infrastructure Engineers to produce a Historic Structure Report (HSR) for the Trestle (PAST Consultants 2007). The purpose of the HSR was to evaluate the potential for rehabilitation of the Trestle for two loading conditions: pedestrian and trolley. The HSR provides a complete historical context, construction history, and significance analysis for the trestle. The HSR concludes that the trestle appears eligible for the National Register and the California Register as an individual historic resource, and also appears eligible as a contributing structure to the National Register -listed Petaluma Historic Commercial District. The Period of Significance for the trestle is r identified as 1922-1992, which includes the original service year for the Trestle through its last year of service. In summary, the report states that the Trestle is significant at the national level under National Register significance Criteria A and B. Under Criterion A, it is historically significant because of its association with Petaluma's time of great economic expansion when it was declared the "World's Egg Basket." The Trestle is a surviving symbol of the agricultural and commercial strength that made the city a prosperous regional transportation center for the movement of agricultural and manufacturing goods throughout Sonoma County, and greater Bay Area. Under Criterion B, it is historically significant for its association with George P.McNear, whose family has left behind an impressive legacy of elegant historic buildings, public open spaces, and even the configuration of the Petaluma River itself. The Trestle appears eligible for the California Register under Criterion 1 for its association with Petaluma's time of greatest growth as the "World's Egg Basket," under the themes of agriculture, industry, commerce and transportation. Under Criterion 2 the Trestle is eligible for its association with George P. McNear, who is indelibly linked to the development of the Petaluma & Santa Rosa Railroad Company and the subsequent construction of the West Petaluma Spur and associated Trestle. The report further concludes that given the Trestle's historic significance, it appears eligible for listing as a contributing structure to the Petaluma Historic Commercial District. For a property to qualify for listing on the National Register not only must the property meet specific significance criteria, it must also possess integrity. Integrity is defined as "the unimpaired ability of a property to convey its historical significance." The National Register recognizes seven aspects or qualities that, in various combinations, define integrity. The seven aspects of integrity are location, design, setting, materials, workmanship, feeling, and association (36 CFR 60). To retain historic integrity a property must possess several, and usually most, of the aspects. Because no such analysis was provided in the above- described studies, a separate historic resource evaluation, titled Petaluma Trestle Historic Resource Evaluation, was conducted for the proposed project (Preservation Architecture 2011). The evaluation concludes that the Trestle retains integrity of location, setting, and association, but the design, materials, and workmanship are disintegrated, and feeling also is partially disintegrated. For a finding of integrity relative to this structure, a greater degree of integrity than exists must be present. Therefore, the evaluation concludes that the Trestle, in its present state, lacks integrity. The consequence of this determination is that, while there are strong bases for historic significance, the property lacks sufficient integrity, so does not individually meet the criteria for listing on the National Register. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 37 The California Register of Historic Resources allows for the inclusion of properties with reduced integrity, and specifically if the resource maintains the potential to yield historical information. The trestle has such potential, as it has strong links to historic activities associated with downtown Petaluma and the Petaluma River, and as it fulfills a unique development pattern within its historic context. Therefore, the 2011 evaluation concludes that the Trestle has a basis for a finding of individual historic significance under California Register criteria 1 and 2, so has sufficient integrity for listing on the California Register. The evaluation also concurs with prior evaluations that the Trestle appears to be eligible as a contributor to the Petaluma Commercial Historic District. V.a and b) Cause Substantial Adverse Change in Significance of Historical Resources or Historic Properties — Less than Significant with Mitigation Archaeological Resources Although previous cultural resources studies did not locate any archaeological resources within the Project's APE, based upon the intensive historic land use in this area, a high potential exists for the presence of buried historic archaeological resources (resources that are not visible on the present ground surface) that could be disturbed during construction -related earth disturbing activities. These activities include the placement of timber piles for the new pedestrian walkway and slope stabilization repair 3. The types of resources that could be present include historic trash deposits; buried foundations or wooden piers; and historic debris, such as bottles and ceramics: and remnants of sunken maritime vessels vessel parts, or cargo. The remaining project construction activities, including use of staging areas, the temporary relocation of the Petaluma Yacht Club boat dock, and the installation of educational features along the waterfront would not affect archaeological resources because these activities would occur on paved areas, on the river, and within other developed areas. Although the potential for encountering prehistoric archaeological resources is low based upon the results of previous studies and the intensive historic use in the area, the possibility of finding such resources cannot be entirely discounted. The potential impact to historical resources and historical properties from project construction is considered significant. Mitigation Measure CR -1: Record Significant Historic Structures Prior to initiation of construction, including any alterations to the trestle, an archaeologist or historian shall officially record the trestle, any wooden piers from older wharfs within the Project APE, and the potential remains of spur tracks on State DPR 523 forms. The completed DPR forms shall be filed at the Northwest Information Center of the California Historical Resources Information System and submitted to the City of Petaluma. Mitigation Measure CR -2: Treatment of Previously Undiscovered Archaeological Materials A qualified archaeologist shall be onsite to monitor initial earth clearing work associated with slope stabilization and pedestrian walkway. An onsite monitor is not necessary during pile driving. If archaeological materials are encountered while the archaeologist is present, or if archaeological materials are encountered during unmonitored construction activities, the piece of equipment that encounters the materials must be stopped, and the find inspected by a qualified archaeologist. In addition, if shipwreck remains, associated artifacts, or cargo are encountered 3 Work on the existing trestle piles is not included as many are below the water's surface and involve hammering piles into the ground with no digging into the River bottom. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated ENIS Proposed MND 0205511002 GHD 38 the find shall be inspected by a qualified maritime archaeologist. Project personnel shall not collect cultural materials. If the archaeologist determines that the find +s- historical s historical resource under CEQA &igp f:Ga-i#, all work must be stopped in the immediate vicinity to allow the archaeologist to evaluate and materials and recommend appropriate treatment. Should any of these materials be discovered during Project construction on lands under the jurisdiction of the California State Lands Commission (CSLC) and the find potentially qualifies as a historical resource under CEQA, the archaeologist shall consult with CSLC staff concerning treatment options. The archaeologist shall also contact the federal lead agency who would follow procedures outlined in 26 CFR 800.13(b)(3), including notifying the SHPO and the Native American representatives as recommend by the Native American Heritage Commission within 48 hours of the discovery to resolve any adverse effects. Such treatment and resolution could include modifying the project to allow the materials to be left in place, or undertaking data recovery of the materials in accordance with standard archaeological methods. Mitigation Measures CR -1 and CR -2 provide the means to identify, record, and treat potentially significant [ historical resources and historic properties that could be present within the APE. Therefore, with mitigation, the project would not cause a substantial adverse change in the significance of a historic resource, and under Section 106 of the National Historic Preservation Act, the project would result in no adverse effect on a historic property. Historic Structures As described above, the Trestle is considered eligible for listing in the California Register of Historic Resources and is considered eligible as a contributor to the National Register -listed Petaluma Historic Commercial District. The trestle therefore meets the definition of historical resource and historic property. The proposed Project would rehabilitate the Trestle in accordance with the Secretary of the Interior's Standards for Historic Preservation (Standards). Rehabilitation is defined as the act or process of making possible a compatible use for a property through repair, alterations, and additions while preserving those portions or features which convey its historical, cultural, or architectural values. According to the Standards, rehabilitation of a historic structure may be considered as a treatment when repair and replacement of deteriorated features are necessary; when alterations or additions to the property are planned for a new or continued use, and when its depiction at a particular period of time is not appropriate. The Project adheres to those Standards for Rehabilitation (Preservation Architecture 2012), which are applicable: 1. The property will be used as it was historically. 2. The historic character of the property will be retained and preserved. 5. Distinctive materials and construction techniques that characterize the property will be preserved. 6. Distinctive historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement, the new feature will match the old in design, color, texture and, where possible, materials. 9. Related new construction will be differentiated from yet compatible with the old. While extensive repair, alteration and selective replacement is proposed, the project would reuse the property and structure as they were historically (Standard 1). The Project also retains historic materials and assemblies (piles, bent caps, stringers, rails) to the maximum feasible extent; replaces materials too City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 39 deteriorated to repair (decking) with new to match the old; and selectively replaces original assemblies (piles, braces) with new materials and assemblies to replicate original forms (Standards 2, 5, 6). The Project would add new construction (guard railings) with new assemblies differentiated from the old (Standard 9). Therefore, the Project would be undertaken in accordance with the Standards for Rehabilitation. Under CEQA, projects that are determined to meet the Secretary of the Interior's Standards for the Treatment of Historic Properties shall be considered to be mitigated to a less than significant impact on the historical resource. Therefore, the Project would have a less than significant impact on historical resources. Under federal regulations 36 CFR Part 800.5, Alteration of a property, including restoration, rehabilitation, repair, maintenance, stabilization, that is not consistent with the Secretary's Standards for the Treatment of Historic Properties (36 CFR part 68) applicable guidelines would constitute an adverse effect on a historic property. Because the Project is consistent with the Standards, the Project would not adversely affect a historic property. Pedestrian Walkway at Historic Spur Location The Draft Conceptual Design Report for Rehabilitation of Petaluma Trestle (Winzler & Kelly 2011 a), does not include the addition of a pedestrian walkway at the location of the historic spur, as described in the Project Description. The pedestrian walkway would not be a standalone feature but would connect the Trestle to the pedestrian path leading to C Street. Therefore, if the pedestrian walkway were included as part of the Project, the Petaluma Trestle Standards Evaluation (Preservation Architecture 2012) would need to be updated to determine whether adding the pedestrian walkway would be compliant with Secretary of Interior Standard 9 and 10, relating to new additions, and therefore whether the Project would still comply with the Standards for Rehabilitation. Standard 9 looks at whether related new construction will be differentiated from yet compatible with the old. Standard 10 looks at whether adjacent or related new construction would be undertaken in a manner that, if removed in the future, the historic property would be unimpaired. The potential impact of the Project on historic resources and historic properties, with the inclusion of the pedestrian walkway, is considered significant. Mitigation Measure CR -3: Update Design Documents and Standards Evaluation If the pedestrian walkway is included in the Project the City shall update the design documents indicating the materials, features, size, scale, and massing of the proposed pedestrian walkway. After the design documents have been updated, the Standards Evaluation will be updated to include the pedestrian walkway and determine if its inclusion in the Project, as proposed in the updated design documents, meets Standards 9 and 10 in the Secretary of the Interior's Standards for Rehabilitation. If it does not, recommendations will be provided and the design modified so that it is in compliance with the Standards for Rehabilitation. If the pedestrian walkway design cannot meet the Standards for Rehabilitation it shall not be included in the Project. Mitigation Measure CR -3 will provide a mechanism for review of the pedestrian walkway to determine its compliance with the Standards for Rehabilitation and if it is found that the Project cannot meet the Standards with inclusion of the pedestrian walkway, then it will not be included as part of the Project. With inclusion of Mitigation Measure CR -3 the Project would have a less -than -significant impact and would not adversely affect a historic resource or property. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 40 V.c) Paleontological Resources — No Impact According to the Petaluma General Plan 2025 EIR (City of Petaluma 2008b) no known significant paleontological resources exist in the City. In addition, Project construction involves a minor amount of earth disturbance. The Project would not impact potentially significant paleontological resources. V.d) Disturb Human Remains — Less than Significant with Mitigation t Although the potential for encountering human remains is low based upon the results of previous studies, the intensive historic use in the area, and the limited amount of ground disturbance needed for the Project, the possibility of finding such materials cannot be entirely discounted. The potential impact to human remains from project construction is considered significant. Mitigation Measure CR -4: Procedures When Encountering Human Remains If human remains are discovered during construction, potentially damaging activities shall be halted and no further excavation of the remains or nearby area until the Sonoma County Coroner has made necessary findings as to origin, in accordance with the Health and Safety Code 7050.5. The City shall immediately notify the County Coroner and a professional archaeologist to determine the nature of the remains. If the Coroner determines that the remains are of Native American origin, the City shall notify the Native American Heritage Commission within 24 hours of identification, as well as the federal agency representative. The disposition of and control over any cultural items excavated or removed shall be determined as provided for in the Native American Graves Protection and Repatriation Act. Implementation of Mitigation Measure CR -4 will provide standard procedures to follow in the event that human remains are encountered during construction. The procedures are in accordance with regulatory requirements for the treatment of human remains, and adherence to these procedures would reduce the potential impacts to less than significant and would result in no adverse effect. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 41 VI. Geology and Soils Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project: a) Expose people or structures to potential X 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 X the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ii. Strong seismic ground shaking? X iii. Seismic -related ground failure, X including liquefaction? iv. Landslides? X b) Result in substantial soil erosion or the loss X of topsoil? c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially X result in on- or off-site lateral spreading, subsidence, liquefaction, or collapse? d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code X (1994), creating substantial risks to life or property? e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems X where sewers are not available for the disposal of wastewater? VI.a.i) Fault Rupture — No Impact The Project site is not located within the zone of a known earthquake fault as delineated under the Alquist-Priolo Earthquake Fault Zoning Act, and is not underlain by any other active or potentially active faults (Miller Pacific 2011). Therefore, no impact from rupture of a known fault would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EAJIS Proposed MND 0205511002 GHD 42 VI.a.ii) Strong Ground Shaking — Less than Significant with Mitigation Earthquakes along several active faults in the region, in particular the Hayward/Rodgers Creek, San Andreas and Maacama/Garberville faults, could cause moderate to strong ground shaking at the Project site (median peak ground accelerations up to 0.33g for the Hayward/Rogers Creek fault) (Miller Pacific 2011). The potential impact from strong groundshaking would be significant, given that the shaking could expose people or structures to substantial adverse effects. Mitigation Measure GEO-1: Implement Site -Specific Geotechnical Recommendations The Project shall be designed and constructed in conformance with the specific recommendations contained in the design -level geotechnical study (Miller Pacific 2011), including recommendations for seismic design, site preparation, grading, trestle pile evaluation, and retaining wall design. The recommendations contained in the geotechnical study shall be incorporated into the final plans and specifications for the Project and implemented during construction. Recommendations contained in the geotechnical study include, but are not limited to, the following: • Seismic design parameters in accordance with the most recent version of the California Building Code. f' Development of a pile load testing program to evaluate and confirm the vertical capacity for evaluation of existing timber piles. i • Replacement of necessary piles using torque -down steel piles or driven concrete or steel piles designed with adequate stiffness to prevent bucking due to vertical and live loads imposed by the structure. • Structurally disconnecting elements which are not supported on the piles to prevent future settlement. • Design of retaining walls bulk heads to resist to the earth pressures and seismic loads in accordance with the geotechnical study. • Design of permanent cut or fill slopes shall not be steeper than 2:1 (horizontal:vertical) inclination, and where possible, shall be at a 3:1 or flatter inclination. Mitigation Measure GEO-1 (Implement Site -Specific Geotechnical Recommendations) will reduce the impact to people and Project structures from strong seismic ground shaking by requiring design and construction in conformance with the specific recommendations contained in the design -level geotechnical study, which includes seismic design recommendations to mitigate the effect of strong ground shaking. The impact from strong seismic ground shaking following mitigation would be less than significant. VI.a.iii) Seismic Related Liquefaction — Less than Significant The Project site is located in an area mapped by the USGS as having moderate to high liquefaction potential associated with alluvial deposits of the Petaluma River (USGS 2006). However, the site-specific data from the geotechnical borings at the Project site indicate that the site would not be susceptible to liquefaction due to the significant clay content of soils encountered and the relatively thin deposits of sand (Miller Pacific 2011). Therefore, potential geologic impacts on people or structures related to liquefaction would be less than significant. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 43 VI.a.iv) Landslides — Less than Significant with Mitigation The Project site is located in an area mapped as flat land, which is defined as areas of gentle slope at low elevation that have little or no potential for the formation of slumps, transitional slides, or earth flows except along stream banks or terrace margins (USGS 1998). The geotechnical investigation confirmed the relatively flat topography of the site, and site-specific data from the geotechnical borings at the Project site did not reveal any substantial shear planes or weak geologic contacts associated with prior landslides that would indicate the potential for global slope instability damage (Miller Pacific 2011). However, as described in the Project Description, localized river bank instability, including sloughing and slope failures adjacent to the Trestle require the placement of a retaining structure. The proposed retaining wall structures would structurally stabilize the river bank. Mitigation Measure GEO-1 (Implement Site -Specific Geotechnical Recommendations) will ensure that the retaining wall structures will be constructed in accordance with geotechnical recommendations. Mitigation Measure GEO-1: Implement Site -Specific Geotechnical Recommendations Mitigation Measure GEO-1 (Implement Site -Specific Geotechnical Recommendations) will reduce the impact to people and Project structures from slope instability by requiring design and construction of retaining walls in accordance with the specific recommendations contained in the design -level geotechnical study. Therefore, by design and intent, the Project will reduce the existing potential for landslides and improve slope stability at the site. The impact following mitigation would be less than significant: VI.b) Soil Erosion or Loss of Top Soil — Less than Significant The Project site is underlain by stream deposits over estuarine deposits (Bay Mud) (Miller Pacific 2011). Project grading would not disturb extensive areas with an intact soil profile. Consequently, no substantial loss of topsoil due to erosion or grading is anticipated during construction or operation of the Project. Construction impacts to water quality associated with the temporary disturbance of the river bed and bank are addressed in Section IX, Hydrology and Water Quality. VI.c) Unstable Soils — Less than Significant with Mitigation The Project site is underlain by stream deposits over moderately thick (8-10 feet) deposits of Bay Mud (Miller Pacific 2011). The site-specific data from the geotechnical borings at the Project site did not encounter loose, granular deposits above the groundwater table that would be susceptible to settlement. However, total and differential settlement can occur when new loads are placed over Bay Mud. Therefore, the potential for settlement due to unstable soils is considered significant. The potential for damage from lateral spreading would be less than significant, given that the geotechnical borings did not indicate the presence of continuous liquefiable soil layers at the Project site (Miller Pacific 2011). Mitigation Measure GEO-1: Implement Site -Specific Geotechnical Recommendations Mitigation Measure GEO-1, described under VI.a.ii, will reduce the impact to people and Project structures from unstable soils by requiring design and construction in conformance with the specific recommendations contained in the design -level geotechnical study, which include recommendations for evaluating and replacing piles that will penetrate the compressible Bay Muds to mitigate the effect of settlement. The impact from unstable soils following mitigation would be less than significant. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 44 VIA) Expansive Soils — Less than Significant The Bay Mud near the ground surface at the Project site is expansive. However, the geotechnical data indicates that the Bay Mud at the site is capped by at least 6 feet of fill, which prevents substantial fluctuations in moisture content, or is located in the river, and would not affect the Project. The impact from expansive soils is therefore considered less than significant. VI.e) Septic Tanks — No Impact The Project would not involve the construction or use of septic tanks or alternative wastewater disposal systems. No impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 45 Vll.a) Generate Greenhouse Gas Emissions — Less than Significant The BAAQMD Air Quality CEQA Guidelines do not include screening criteria or significance thresholds for greenhouse gas emissions from construction. Therefore, this analysis uses a qualitative approach in accordance with Section 15064.4(a)(2) of the CEQA Guidelines. During construction GHG emissions would be generated from construction equipment. However, construction would last for only five months and would be less intensive than traditional land use development that requires a larger fleet of earthmoving equipment or soil off hauling and/or delivery and similar such equipment. In addition, as noted in the Project Description, applicable BAAQMD Basic Construction Measures would be included in the Project design and implemented during construction. These measures include the following: 1) idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes; and 2) all construction equipment shall be maintained and properly tuned in accordance with manufacturer's specifications and checked by a certified visible emissions evaluator. The Proiect does not include a traditional construction fleet (earthmoving equipment backhoes loaders) that is typically measured when modeling GHG emissions for land development construction Construction of the Trestle would include a tug boat to tow the barge into place either an impact hammer or vibratory hammer, and a generator to power small handheld equipment. Given the short construction period (five months),_ the small quantity of construction equipment to be used, and the inclusion of the Basic Construction Measures in the project design, the impact to GHG emissions during construction is considered less than significant. The only energy that would be used during Project operation would be electricity for the nighttime lighting that may be installed for safety purposes. This use would generate a negligible amount of indirect GHG emissions. This impact to GHG emissions is considered less than significant. VII.b) Conflict with Applicable Plan, Policy or Regulation — No Impact The City of Petaluma has adopted numerous GHG emission reduction policies and programs as part of the General Plan 2025 (City of Petaluma 2008a). These policies and programs deal with energy efficiency, transportation, a climate action plan, and educational programs. Most of these policies and programs do not relate to an infrastructure project like the Trestle Rehabilitation Project. However, Policy City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 46 Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact VII. Greenhouse Gas Emissions Would the project: a) Generate greenhouse gas emissions, either directly or indirectly, that may have X a significant impact on the environment? b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of X reducing the emission of greenhouse gases? Vll.a) Generate Greenhouse Gas Emissions — Less than Significant The BAAQMD Air Quality CEQA Guidelines do not include screening criteria or significance thresholds for greenhouse gas emissions from construction. Therefore, this analysis uses a qualitative approach in accordance with Section 15064.4(a)(2) of the CEQA Guidelines. During construction GHG emissions would be generated from construction equipment. However, construction would last for only five months and would be less intensive than traditional land use development that requires a larger fleet of earthmoving equipment or soil off hauling and/or delivery and similar such equipment. In addition, as noted in the Project Description, applicable BAAQMD Basic Construction Measures would be included in the Project design and implemented during construction. These measures include the following: 1) idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes; and 2) all construction equipment shall be maintained and properly tuned in accordance with manufacturer's specifications and checked by a certified visible emissions evaluator. The Proiect does not include a traditional construction fleet (earthmoving equipment backhoes loaders) that is typically measured when modeling GHG emissions for land development construction Construction of the Trestle would include a tug boat to tow the barge into place either an impact hammer or vibratory hammer, and a generator to power small handheld equipment. Given the short construction period (five months),_ the small quantity of construction equipment to be used, and the inclusion of the Basic Construction Measures in the project design, the impact to GHG emissions during construction is considered less than significant. The only energy that would be used during Project operation would be electricity for the nighttime lighting that may be installed for safety purposes. This use would generate a negligible amount of indirect GHG emissions. This impact to GHG emissions is considered less than significant. VII.b) Conflict with Applicable Plan, Policy or Regulation — No Impact The City of Petaluma has adopted numerous GHG emission reduction policies and programs as part of the General Plan 2025 (City of Petaluma 2008a). These policies and programs deal with energy efficiency, transportation, a climate action plan, and educational programs. Most of these policies and programs do not relate to an infrastructure project like the Trestle Rehabilitation Project. However, Policy City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 46 4-P-16 addresses reducing combustion emissions during construction. It encourages use of the same Basic Construction Measures that are identified in the Project Description and that would be included in project design. Therefore, the Project would not conflict with an applicable plan for reducing GHG emissions. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 47 VIII. Hazards/Hazardous Materials Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project: a) Create a significant hazard to the public or the environment through the routine X transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions X involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, X substances, or waste within one-quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code § 65962.5 X and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport X or public use airport, would the project result in a safety hazard for people residing or working in the project area? f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the X project area? g) Impair implementation of, or physically interfere with, an adopted emergency X response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are X adjacent to urbanized areas or where residences are intermixed with wildlands? City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 48 Vlll.a and b) Create Significant Hazard to the Public or Environment from transport, use, disposal, or release of Hazardous Materials — Less than Significant with Mitigation Operation of the project would not involve the transport, use or disposal of hazardous materials that could be released into the environment. There would be no impact from operation of the Project. Construction would require the use of hazardous materials such as fuels, lubricants, and solvents. Numerous laws and regulations ensure the safe transportation, use, storage and disposal of these j materials including the federal Resource Conservation and Recovery Act and Hazardous Materials Transportation Act and California's Hazardous Waste Control Law. Contractors would be required to comply with existing and future hazardous materials laws and regulations for the transport, storage, labeling, use and disposal of hazardous materials. Therefore, the potential to create a significant hazard to the public or the environment from the use of fuels, lubricants, and solvents during construction activities would be less than significant. The Trestle is primarily composed of wood, much of which has been treated with creosote. The creosote treated wood that is not being re -used or repaired would need to be disposed of during construction. Under California's Hazardous Waste Control Law the wood is considered Treated Wood Waste (TWW). Because TWW contains hazardous chemicals, at elevated levels, it is subject to California's Hazardous Waste Control Law. The Department of Toxic Substances Control (DTSC) has developed alternative management standards (AMS) for TWW that are based upon full hazardous waste requirements but are adjusted for the unique circumstances associated with TWW4. The potential hazard that could result from the transport or disposal of the TWW is considered a significant impact without mitigation. Mitigation Measure HM -1: Disposal of Treated Wood Waste The Contractor shall comply with the Department of Toxic Substances Control alternative management standards for Treated Wood Waste found in California Code Regulations (Cal. Code Regs.) title 22, division 4.5, chapter 34. If temporary storage of treated wood waste will occur on-site, it shall be listed on a Hazardous Materials Business Plan and submitted to the Fire Marshal. The AMS simplify and facilitate the safe and economical disposal of TWW as described in the Requirements for Generators of Treated Wood Waste (Department of Toxic Substances Control 2008). With implementation of Mitigation Measure HM -1, the impact would be less than significant. For the reuse of creosote treated wood in the aquatic environment, refer to IX Hydrology and Water Quality. Vlll.c) Emit Hazardous Emissions within One-quarter Mile of a School — No Impact Project operation would not emit hazardous emissions and no schools are located within % mile of the Project Site (City of Petaluma 2008a). There would be no impact to schools. 4 TWW that is considered RCRA hazardous waste is not eligible for AMS. The testing results summarized in the Results of Hazardous Material Survey: Petaluma Trestle Rehabilitation Project (Winzler & Kelly 2011 b) determined Trestle demolition waste is highly unlikely to require disposal as a RCRA hazardous waste. The detected analytes were significantly below the regulatory levels. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 49 VIIIA) Included on List of Hazardous Materials Sites — No Impact The Project is not located on a site which is included on a list of hazardous materials sites (State Water Resources Control Board: Geotracker 2012). The closest listed hazardous materials site (a leaking underground storage tank cleanup site) is approximately 225 feet to the southeast of the Project site. The State Water Resources Control Board files indicate that the cleanup of the site has been completed and the case is closed. Therefore, construction and operation of the Project would not create a hazard to the public or environment. Vlll.e and f) Result in Safety Hazard for People Residing or Working within Airport Land Use plan or within Two Miles of Public Airport, or Private Airstrip — No Impact The Project site is not located within two miles of a public airport or a private airstrip. The nearest such facility is Petaluma Municipal Airport approximately 2.25 miles to the northeast on Washington Street. The Project site also is outside the airport's land use referral boundary (Sonoma County 2001). Therefore, the Project would not expose people residing or working in the Project area to an airport safety hazard and there would be no impact. Vlll.g) Impair or Interfere with an Adopted Emergency Response/Evacuation Plan — No Impact The Project site is located along the edge of the Petaluma River. Construction would not block a roadway or access to the surrounding streets and businesses. Operation of the project would open the Trestle promenade to pedestrian traffic once again. In addition, if the pedestrian walkway adjacent to the Trestle is implemented as part of the Project it would allow for ingress/egress on the southeast side of the Trestle. Currently access is at one point only: on the west side at the Balshaw Bridge. Neither Project construction nor operation would interfere with an emergency response or evacuation plan. Vlll.h) Exposure to Wildland Fires — No Impact The Project is not located in, or near, land mapped as a "very high" fire hazard severity zone by CALFIRE, or as a "community at risk" for wildland urban interface fire threat mapped by ABAG (ABAG 2003). No impact from wildland fires would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 50 IX. Hydrology and Water Quality Potentially Significant Impact/Effect Less than Si nificant g With Mitigation Less than Significant Impact No Impact Would the project: a) Violate any water quality standards or X waste discharge requirements? b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or lowering of the local groundwater table X 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)? c) Substantially alter the existing drainage pattern of the site or area, including the alteration of the course of stream or river, X in a manner which would result in substantial erosion or siltation on- or off- site? d) Substantially alter the existing drainage pattern of the site or area, including the alteration of the course of stream or river, or substantially increase the rate or X amount of surface runoff, in a manner which would result in flooding on- or off- site? e) Create or contribute runoff water which would exceed the capacity of existing or X planned stormwater drainage systems? f) Otherwise substantially degrade water X quality? g) Place housing within a 100 year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood X Insurance Rate Map or other flood hazard delineation map? h) Place within a 100 year flood hazard area structures which would impede or redirect X flood flows? i) Expose people or structures to a significant risk of loss, injury or death X involving flooding, including flooding as a result of the failure of a levee or dam? City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 51 Potentially Less than Less than IX. Hydrology and Water Quality Significant Significant Significant No Impact/Effect with Impact Impact Mitigation j) Inundation by seiche, tsunami, or mudflow? X IX.a and f) Violate Water Quality Standard or Waste Discharge Requirement or substantially Degrade Water Quality — Less than Significant with Mitigation The Project would not disturb more than 1 acre of land; therefore, compliance under the General Permit for Discharges of Storm Water Runoff Associated with Construction and Land Disturbance Activities does not apply. The Project does not involve dewatering or discharge to a sanitary sewer. A vibratory or impact hammer may be required for installation of the some of the timber piles. This method of construction can cause disturbance of bottom sediment and increased turbidity. In addition, because construction work would occur above, and immediately adjacent to, the Petaluma River, the potential exists for construction debris or fuels to inadvertently enter the water. The potential for increased turbidity and contamination of the river with construction debris or fuels is considered a significant impact on water quality. Mercury entering the water column during sediment disturbance was raised as a potential impact in a letter received from the State Lands Commission during circulation of the June 2012 EA/IS Although the Petaluma River is on the State's 303(d) list for Impaired Water Bodies for sediment/siltation it is not on the list for mercury. Sediment samples taken in support of the decision for not listing mercury showed no exceedance of the water quality objectives for mercury (State Water Board 2010) In addition the USGS Mineral Resources Data System does not identify any mercury deposits in the Petaluma River watershed upstream of the Project site (USGS 2012). Therefore it is unlikely that natural or man-made mercury is present in the sediment at the Project site in such concentrations that sediment disturbance from the Project would release sufficient mercury into the Petaluma River that would cause a significant impact from conversion to methylmercury and consequent bioaccumulation and toxicity. Some creosote -treated components of the Trestle would be reused for rehabilitation of the Trestle. Creosote is a distillate of coal tar with a varying chemical composition depending on the source of the coal tar. The most common creosote chemical compounds are polycyclic aromatic hydrocarbons (PAHs). U.S. EPA lists the top 17 aromatic hydrocarbons typically found in creosote, seven of which are classified as probable human carcinogens. PAHs are known to leach for the life of the wood. (Stratus Consulting 2006) The impact on water quality from reuse of the creosote -treated wood components within the aquatic environment is considered significant. Mitigation Measure HWQ-1: Water Quality Construction Measures The Contractor shall implement the following measures during construction. 1. A sediment curtain shall be installed and utilized around the Trestle structure during pile repair and installation. The curtain shall be inspected daily and maintained to function for its intended purpose. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 52 2. No construction material, including asphalt, concrete, wood, chemicals, or fuels shall be discharged directly or drained indirectly to the Petaluma River from the construction or staging areas. 3. A floating debris barrier (or the sediment curtain installed during pile installation could be used) shall be placed as needed around and beneath the work areas to capture any debris that could accidentally be released from the work area. The debris boom shall be deployed and maintained to prevent any floating debris from escaping the work area. At the end of each work day, any floating debris within the barrier shall be removed. 4. Construction equipment shall be maintained and fuelled in the staging areas only. Equipment shall not be fuelled on the trestle or over the water. Spill containment and cleanup materials shall be maintained on-site through the duration of the work. 5. Equipment shall be inspected daily by the operator for leaks or spills. If leaks or spills are encountered, they shall be cleaned up, and the cleaning materials shall be collected and shall be properly disposed. The source of the leak shall be identified prior to operating the equipment, and the project foreman shall document the resolution of the leak. Spills shall be cleaned up immediately using spill response equipment. Mitigation Measure HWQ-2: Reuse of Creosote Treated Wood in Aquatic Environment r' The contractor shall encapsulate (wrap, coat, or sleeve seal) all creosote -treated wood f components that are to be reused within the aquatic environment up to the MHHW line. These components shall include piles, and sash and sway bracing. The treatment chosen shall encapsulate the wood and prevent leaching of contaminants. The coating must be inert, impervious and long lasting. Implementation of Mitigation Measure HWQ-1 will contain turbidity, prohibit discharge of construction materials to the Petaluma River, and provide containment or clean-up in the event of accidental discharge. Implementation of Mitigation Measure HWQ-2 will create a barrier between the creosote - treated wood and the water thus preventing leaching of contaminants. Sash and sway bracing will be encapsulated in the staging area prior to reuse on the Trestle Piles will be encapsulated in-place The impact to water quality is considered less than significant with mitigation. IX.b) Substantially Deplete Groundwater Supplies or Interfere with Groundwater Recharge — No Impact Neither construction nor operation of the Project would involve the use of groundwater supplies. Construction of the Project would not interfere with groundwater recharge as it does not include the addition of impervious areas. There would be no impact to groundwater. IX.c, d and e) Substantially Alter Existing Drainage Pattern of Site Resulting in Erosion, Siltation, Flooding or Exceed Capacity of Storm Drain System — No Impact Implementation of the Project would rehabilitate an existing structure within the Petaluma River. The massing of the structure would be modified slightly by increasing the diameter of the existing 173 piles from 14 inches to 20 inches. Addition of the pedestrian walkway would increase the number of piles by approximately 6 percent. The flow of the river would be unchanged with implementation of the Project. The Project site does not drain to a storm drain system. Installation of the slope stabilization component City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 53 of the Project would repair the existing sloughing and slope failures adjacent to the Trestle. Erosion, siltation, and flooding would not be substantially altered with implementation of the Project. IX.g) Place Housing within a 100 -Year Flood Hazard Area — No Impact The Project would not place housing within a 100 -year flood area. IX.h) Place structure within 100 -Year Flood Hazard Area which would Impede or Redirect Flows — No Impact The Trestle is located within the 100 -year flood boundary of the Petaluma River. However, it is an existing structure, rehabilitation of which would not impede or redirect flows from current conditions. There would be no impact. IM) Flooding from a Levee or Dam — No Impact The Project site is not located within the inundation zone of a levee or dam. There would be no impact. IXJ) Inundation by Seiche, Tsunami, or Mudflow — No Impact Potential inundation by tsunami and seiche is considered low given the Project site is not directly exposed to an open ocean, bay, or large reservoir. The Project site is not in an area likely to produce mudflow. No impact from tsunami, seiche, or mudflow would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 54 X. Land Use and Planning Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project: a) Physically divide an established community? X b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to, the General Plan, Zoning X Ordinance, or any specific plan) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict with any applicable habitat conservation plan or natural community X conservation plan? Land Use Designations The Project site is zoned as FW - floodway. Construction in the floodway is limited by the Petaluma implementing Zoning Ordinance to activities that will not significantly affect the flow of water (City of Petaluma 2003). The General Plan prohibits new development in the floodway (City of Petaluma 2008a). Land immediately adjacent (south) to the Project site has a City of Petaluma General Plan and Central Petaluma Specific Plan land use designation of Mixed Use and a zoning designation of T5 - Urban Center. Land Use Policies City of Petaluma General Plan The City's General Plan includes goals, policies and programs adopted for the purpose of avoiding or mitigating an environmental effect. The General Plan identifies the trestle as a visual landmark, which provides identity to the City, and the downtown area as a unique and special area. Goals, policies and programs applicable to the Project include: developing land use in proximity to the Petaluma River to enable public access; developing the Petaluma River as a publicly -accessible green ribbon and by implementing the Petaluma River Access and Enhancement Plan; creating and maintaining, in perpetuity, public access sites along the River; providing additional pedestrian/bicycle access to and along the riverfront to connect to existing and future trails toward downtown; maintaining landmarks and aspects of Petaluma's heritage that foster its unique identity, including adaptively reutilizing, reusing and preserving the Petaluma & Santa Rosa Railroad trestle; encouraging and supporting the rehabilitation and development of structures reflective of Petaluma's river -oriented industrial past and present, such as the trestle as a boardwalk and/or trolley line. Petaluma River Access and Enhancement Plan The Petaluma River Access and Enhancement Plan (Access and Enhancement Plan) establishes the community's vision for the Petaluma River, riverfront uses, activities and developments. The General City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 55 Plan implements the objectives and policies presented in the Plan. One of the guiding concepts of the plan is the development of a continuous trail system along the river corridor, that includes interpretive signs, direct water access points, and ties to the Bay Area Ridge Trails and Bay Trails. Trail policies in the River Access and Enhancement Plan include: the designation of all trails bordering the Turning Basin as pedestrian only; and the conversion of all rail corridors to trail use wherever possible. The Access and Enhancement Plan also discusses the importance of water access and identifies opportunities to expand water access, including additional boardwalks, docks, benches, interpretive signs and landscaping at and around the Turning Basin; establishing the Turning Basin as an outdoor gathering place; and because the Turning Basin is prominently featured, visual landscaping (rather than habitat enhancing vegetation) may be permitted. Other relevant policies include: protecting historic buildings along the riverfront; allowing creative re -use of old structures; and in the Warehouse District, retaining old wood pilings and railroad tracks as visual reminders of the history of the area, as long as they do not pose a threat to safety of new activities. Former rail traffic on the railroad trestle is characterized as an obstacle to public access and use of the trestle, and the Plan calls for the City to secure the use of the trestle to complete the waterfront promenade, while acknowledging that interest has also been expressed for keeping the rail line operating for public transit. Central Petaluma Specific Plan The City's Central Petaluma Specific Plan (Specific Plan) aims to direct new growth into the Specific Plan planning area and reconnect the community to the Petaluma River through improving public access while retaining the working waterfront industries. The Specific Plan identifies the Trestle as an important, historical visual landmark, and calls for the restoration of the Trestle, as it "provides historic interest and a very important special framing of the Turning Basin.". Goals, objectives and policies applicable to the Project are presented in the land use, community design, public space and river access, circulation, and historic preservation chapters of the Specific Plan. These include: promoting a strong urban center focused on the Petaluma River Turning Basin; developing a heritage trolley service; activating the old Petaluma & Santa Rosa (P&SR) railroad right-of-way for the heritage trolley route; maintaining visual landmarks; establishing continued, interconnected public spaces and a recreational loop along both sides of the river and Turning Basin (including a safe bike path parallel to the existing rail corridor); establishing a pedestrian -oriented promenade around the Turning Basin and providing special events and activities oriented to the river; and providing a linked system of pedestrian and bicycle routes, including on -street connections to the River Trail. City of Petaluma Bicycle & Pedestrian Plan The City of Petaluma Bicycle & Pedestrian Plan (Bike & Pedestrian Plan) identifies the top priority multi- use trail projects for the City. The River Trail project extends along the length of the Petaluma River within the City limits; the gap between Washington Street and Lakeville Street is identified as the segment most critical to complete. The Bike & Pedestrian Plan also considers the possibility of a rail -with -trail along the proposed trolley line between the Petaluma Village Premium Outlets and the Foundry Wharf. X.a) Physically Divide an Established Community — No Impact The Project site is an existing trestle structure on the Petaluma River waterfront. The Project would rehabilitate the Trestle to provide safe waterfront public access for pedestrians and bicyclists. The Project would not physically divide an established community, and would provide a public access connection along the southern Petaluma River waterfront in the downtown area. No impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 56 X.b) Conflict with Applicable Land Use Plans, Policies or Regulations — No Impact Consistent with the zoning designation for the Project site as floodway, the Project does not involve new development in the floodway, and would not significantly affect the flow of the Petaluma River. Rehabilitation of the existing Trestle to provide public access along the waterfront would complement the Urban Center zoning and Mixed Use land use designation of adjacent lands. } The Project implements The Petaluma River Access and Enhancement Plan, and is consistent with the Central Petaluma Specific Plan by expanding river access; creatively reusing the Trestle for pedestrians access; and protecting the Trestle's historic character through rehabilitation, including retaining the old wood pilings and other elements, to the extent feasible, as reminders of the history of the area. The General Plan goals, policies and programs that are supported by the Project include the following: I developing land use in proximity to the Petaluma River to enable public access; maintaining landmarks and aspects of Petaluma's heritage that foster its unique identity, including adaptively reutilizing, reusing and preserving the Petaluma & Santa Rosa Railroad trestle; and encouraging and supporting the j rehabilitation and development of structures reflective of Petaluma's river -oriented industrial past and present. X.c) Conflict with any Applicable Habitat Conservation Plan — No Impact There are no habitat conservation plans or natural community conservation plans for the Project area. No impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 57 XI. Mineral Resources Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project: a) Result in the loss of availability of a known mineral resource that would be of value to X the region and the residents of the state? b) Result in the loss of availability of a locally - important mineral resource recovery site X delineated by the General Plan, specific plan, or other land use plan? XI.a) Result in the Loss of Availability of a Known Mineral Resource of Value to the Region — No Impact There are no active mines, mineral processing plants or mineral resources identified within the boundaries of the Project. The Project would not result in an impact to any known mineral resource of value to the region. XI.b) Result in the Loss of Availability of a Locally Important Mineral Resource Delineated by a General Plan, Specific Plan or other Land Use Plan — No Impact There are no State -designated (MR -Z-2) mineral resources located at the Project site or in the general vicinity (Sonoma County 1998). The Project would not result in the loss of availability of a locally important mineral resource delineated by a General Plan, Specific Plan or other land use plan. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 58 XII. Noise Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project result in: a) Exposure of persons to or generation of noise levels in excess of standards established in the General Plan or noise X ordinance, or applicable standards of other agencies? b) Exposure of persons to, or generation of, excessive ground borne vibration or ground X borne noise levels? c) A substantial permanent increase in ambient noise levels in the project vicinity X above levels existing without the project? d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity X above levels existing without the project? e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport X or public use airport, would the project expose people residing or working in the project area to excessive noise levels? f) For a project within the vicinity of a private airstrip, would the project expose people X residing or working in the project area to excessive noise levels? City of Petaluma General Plan 2025 The City of Petaluma General Plan 2025 sets forth the following policies related to community noise control applicable to the Trestle Rehabilitation Project: Policy 10-P-3 Protect public health and welfare by eliminating or minimizing the effects of existing noise problems, and by minimizing the increase of noise levels in the future. A. Continue efforts to incorporate noise considerations into land use planning decisions, and guide the location and design of transportation facilities to minimize the effects of noise on adjacent land uses. D. Continue to require control of noise or mitigation measures for any noise -emitting construction equipment or activity. The City's Noise Ordinance establishes controls on construction -related noise. E. As part of development review, use Figure 10-2: Land Use Compatibility Standards to determine acceptable uses and installation requirements in noise impacted areas. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 59 G. In making a determination of impact under the California Environmental Quality Act (CEQA), consider an increase of 4 or more dBA to be "significant" if the resulting noise level would exceed that described as normally acceptable for the affected land use in Figure 10-2: Land Use Compatibility for Community Noise Environments. City of Petaluma Noise Ordinance The Petaluma Noise Ordinance is contained in Implementing Zoning Ordinance 2300, Chapter 21, Performance Standards. The purpose "is to protect properties and the general health, safety, and welfare of persons from unnecessary, excessive, and annoying noise disturbances." Section 21.040 A.3.a declares that the use of specific tools, and "construction, demolition, excavation, alteration, and repair activity" generally are a public nuisance before 7:00 a.m. or after 10:00 p.m. daily (except Saturday, Sunday and State, Federal or Local Holidays, when the prohibited time shall be before 9:00 a.m. and after 10:00 p.m.). Section 21.040 A.4.c declares that "No person shall cause or allow to cause, any source of sound ..., which when measured on the property where the noise disturbance is being experienced..., exceeds the noise level of Table 21.1. The ordinance includes provisions for adjusting the limits where ambient noise levels exceed the limits. Section 21.040.A.5.e exempts "uses established through the discretionary review process containing specific noise conditions of approval and/or mitigation measures." Xll.a) Exposure of Persons to Noise Levels in Excess of Established Standards — Less than Significant Noise and Land Use Compatibility Noise and land use compatibility refers to the development of noise sensitive uses in noisy environments. The Trestle Rehabilitation Project is not a noise sensitive land use and, therefore, would be compatible with the surrounding land uses. There would be no impact upon the Project or surrounding uses. Noise from Construction Activities Demolition and construction activities necessary to implement the Project would generate noise. The Noise Ordinance (which is incorporated into the City of Petaluma Community Development Department's Implementing Zoning Ordinance) declares that construction activities before 7:00 am or after 10:00 pm are a public nuisance and prohibited. As noted in the Project Description, construction hours would be from 7am to 5pm, which is within the allowable hours in the Noise Ordinance. There would be no impact from conflict with the Noise Ordinance relative to construction. Operational Noise The Project is the rehabilitation of the Trestle structure. Since closing of the Trestle, pedestrian and bicycle traffic has shifted to the areas adjacent to the Trestle. After the rehabilitation is completed, the Trestle would once again be open for pedestrian and bicycle use. Therefore, no change would occur in the noise environment due to the Project, and there would be no significant operational noise resulting from the Project. Xll.b) Exposure to Groundborne Vibration or Noise — Less than Significant with Mitigation This analysis uses a significance threshold for vibration of 0.5 inches/second, peak particle velocity (in/sec, PPV) for buildings that are structurally sound and designed to modern engineering standards; 0.3 in/sec, PPV for older residential buildings; 0.25 for historic and some old buildings and a conservative limit of 0.08 in/sec, PPV for ancient buildings or buildings that are documented to be structurally weakened (as established by the California Department of Transportation). City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 60 Table XII -1 presents typical vibration levels that could be expected from construction equipment at a distance of 25 feet. Table XII -1: Vibration Source Levels for Construction Equipment Equipment PPV at 25 ft. (in/sec) Pile Driver (Impact) upper range 1.158 typical 0.644 Pile Driver (Sonic/Vibratory) upper range 0.734 typical 0.170 Clam shovel drop 0.202 Hydromill (slurry wall) in soil 0.008 in rock 0.017 Vibratory Roller 0.210 Hoe Ram 0.089 Large bulldozer 0.089 Caisson drilling 0.089 Loaded trucks 0.076 Jackhammer 0.035 Small bulldozer 0.003 Source: Transit Noise and Vibration Impact Assessment, United States Department of Transportation, Federal Transit Agency, Office of Planning and Environment, May 2006. The trestle is comprised of 35 bents with 173 timber piles that would be replaced or repaired, with a few being preserved. In addition, approximately 16 new piles could be installed to support the potential pedestrian walkway. Slope stabilization is required adjacent to the trestle for a length of approximately 50 to 75 feet. There are two slope repair alternatives that would utilize either vertical H -piles (that would be installed using a rotary drill) or vertical sheet piles (using a vibratory hammer or hydraulic, low impact press -in method). The construction methods for preserving trestle piles or repairing trestle piles would not involve methods that would generate significant ground -borne vibration levels. A vibratory hammer would be used to vibrate out the damaged piles that would be replaced. If the existing, damaged piles can be completely removed, new timber piles would be installed. A vibratory or impact hammer would be required for installation of the timber piles. If a damaged pile cannot be removed, it would be broken or cut at or below the mudline. If a broken or cut pile is found to be deteriorated below the cut line, a steel pile will be driven over the "stump." An impact or vibratory hammer and crane barge would be used to install the pile. If the pile is found to be sound below mudline, a steel pile sleeve would be placed over the pile stump. The steel sleeve would be installed using a crane or with smaller equipment. A new timber pile section would then be attached to the steel pile sleeve and would support the bent cap. The only significant source of ground vibration associated with the Project would result from vibratory or impact pile driving—including timber pile driving for the Trestle and pedestrian walkway, and sheet pile City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 61 driving for the slope stabilization. Vibration levels are highest close to the source, and then attenuate with increasing distance at the rate (D,f/D)1.1, where D is the distance from the source in feet and Dref is the reference distance of 25 feet. Given the small size of the piles and the overall range of piles, the "typical' values shown in Table XII -1 would provide a credible worst case level for anticipated pile driving vibration. Using the attenuation rate above, the use of an impact pile driving hammer is calculated to result in levels exceeding 0.25 inch/sec PPV at a distance of up to about 60 feet, and for a vibratory hammer at a distance of up to 20 feet. The nearest sensitive receptor is a portion of the Great Petaluma Mill building; where a pile could be driven 12 feet from the building. At a distance of 12 feet the vibration levels for impact and vibratory pile driving are calculated to be 1.44 in/sec PPV and 0.38 in/sec PPV respectively. All other buildings adjacent to the project are located at distances from approximately 25 to 40 feet, where vibration levels from impact driving would range from 0.644 to 0.384 in/sec PPV and vibration levels from vibratory driving would be equal to or less than 0.17 in/sec PPV. If an impact or vibratory hammer is used, then the vibration from pile driving could potentially be significant within 60 and 20 feet respectively. See Section IV, Biological Resources, regarding underwater noise impacts.) Mitigation Measure NO -1: Construction Vibration Impact If feasible the contractor shall utilize a vibratory pile driving hammer. If an impact hammer is used, or when a vibratory hammer is used and a building is located within 20 feet of the pile, then the following shall be implemented: The City shall conduct a pre -project crack survey of adjacent buildings within 60 feet, documenting existing conditions. During impact pile driving, the City shall monitor ground vibration levels outside adjacent buildings to confirm vibration levels are below the allowable level of 0.25 inch/sec PPV. If vibration levels exceed the allowable level, the City shall conduct a post construction crack survey and repair any cosmetic damage (i.e. hairline cracking) resulting from the project. Implementation of Mitigation Measure NO -1 will allow for documentation of existing conditions, monitoring of vibration, and provide a means to repair potential minor cosmetic damage. Mitigation Measure NO -1 will reduce the impact to less than significant. Xll.c) Substantial Permanent Increase in Ambient Noise — No Impact Once the trestle rehabilitation is completed, the trestle could be open for pedestrian and bicycle use, as it was before the trestle was closed. The area is currently used for pedestrian and bicycle traffic adjacent to the trestle. These activities would cause no measureable change in the noise environment in the area. There would be no impact. Xll.d) Substantial Temporary Increase in Ambient Noise — Less than Significant with Mitigation Construction is expected to last from four to five months. The in -water construction work window is expected to be from June 15 to October 30, with impact hammer pile driving limited to August J UI 1 through September 309stebe_-4e. Construction activities generate considerable amounts of noise. Typical construction noise levels are shown in Table XII -2. Construction -related noise levels are normally highest during the demolition phase and during the phases of construction requiring heavy equipment. Typical hourly average construction - generated noise levels are about 81 to 88 dBA Leq measured at a distance of 50 feet from the center of the site during busy construction periods. A vibratory pile driver generates a steady noise level of about 95 dBA Lmax/Leq at a distance of 50 feet, and an impact pile driver generates an intermittent noise level of City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 62 up to 105 dBA Lma,, at a distance of 50 feet. The average noise level of an impact pile driver is about 95 dBA Leq. There would be variations in construction noise levels on a day-to-day basis depending on the actual activities occurring at the site. Construction generated noise levels increase or decrease at a rate of about 6 dBA per halving or doubling of distance, respectively, between the source and receptor. The nearest sensitive receivers are restaurants adjacent to the trestle, particularly the outdoor dining areas. The Lofts at Basin Street Landing apartments adjoin the Project site between B Street and C Street. The apartments are located on the 2nd and 3rd floors, 25 feet from the Project site at its closest point. Hourly average outdoor noise levels could reach 100 dBA Leq during impact hammer pile driving when adjacent to a receptor. Although Project construction would be limited to 4 to 5 months, the impact on outdoor dining areas during lunch and dinner hours would be significant. There are no other outdoor areas sensitive to noise in the near vicinity. Noise levels inside the nearest buildings would be about 25 to 30 dBA lower than the exterior levels due to the attenuation provided by the building. Residents would be exposed to elevated noise levels during the daytime intermittently throughout the 4 to 5 month construction period. Table XII -2: Construction Equipment 50 -Foot Noise Emission Levels Equipment Category Lmax Level (dBA)1,2 Impact/Continuous Arc Welder 73 Continuous Auger Drill Rig 85 Continuous Backhoe 80 Continuous Bar Bender 80 Continuous Boring Jack Power Unit 80 Continuous Chain Saw 85 Continuous Compressor' 70 Continuous Compressor (other) 80 Continuous Concrete Mixer 85 Continuous Concrete Pump 82 Continuous Concrete Saw 90 Continuous Concrete Vibrator 80 Continuous Crane 85 Continuous Dozer 85 Continuous Excavator 85 Continuous Front End Loader 80 Continuous Generator 82 Continuous Generator (25 KVA or less) 70 Continuous Gradall 85 Continuous Grader 85 Continuous Grinder Saw 85 Continuous Horizontal Boring Hydro Jack 80 Continuous Hydra Break Ram 90 Impact Impact Pile Driver 105 Impact Insitu Soil Sampling Rig 84 Continuous Jackhammer 85 Impact Mounted Impact Hammer (hoe ram) 90 Impact Paver 85 Continuous Pneumatic Tools 85 Continuous Pumps 77 Continuous Rock Drill 85 Continuous Scraper 85 Continuous Slurry Trenching Machine 82 Continuous Soil Mix Drill Rig 80 Continuous Street Sweeper 80 Continuous Tractor 84 Continuous Truck (dump, delivery) 84 Continuous Vacuum Excavator Truck vac -truck 85 Continuous City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 63 Equipment Category Lmax Level (dBA)1'2 Impact/Continuous Vibratory Compactor 80 Continuous Vibratory Pile Driver 95 Continuous All other equipment with engines larger than 5 HP 85 Continuous ivoies: 1 Measured at 50 feet from the construction equipment, with a "slow" (1 sec.) time constant. 2 Noise limits apply to total noise emitted from equipment and associated components operating at full power while engaged in its intended operation. a Portable Air Compressor rated at 75 cfm or greater and that operates at greater than 50 psi. A construction staging area would be locatedarepesed in the paFking area at the north end of Cir + M r Street adjaGeRt +c the Petaluma Yacht Club and along Water Street just north of the Balshaw Pedestrian Bridge immediately adjacent to the Water Street Bistro Restaurant outdoor dining area. Activities in the staging area would include delivery and handling of materials. 0 mmediately adjaGGRt tG the Water Street Bistre Restaurant eutdoel: diniRg area. Noise resulting from activities in the staging area would be intrusive, particularly during the lunchtime when the outdoor dining area is used most intensively. Outdoor noise impacts could be significant without mitigation. Mitigation Measure NO -2: Construction Noise Impact The City shall reduce noise levels to the extent feasible during construction, by implementing the following: 1. Prepare and implement a Noise and Vibration Control Plan to reduce construction noise levels at nearby noise -sensitive land uses. The contractor shall contact the potentially affected sensitive receptors and notify them of the construction schedule. The Plan shall identify best available noise and vibration control practices (including the type of pile driving equipment, mufflers, intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds) which shall be used for all equipment and trucks in order to minimize construction noise impacts. 2. Schedule pile driving to minimize impacts on nearby restaurants and apartments. Allowable hours for pile driving shall be Monday — Friday 7:45 a.m. to 11:45 a.m. and 2:00 p.m. to 5:00 p.m. to avoid lunch and dinner periods unless different hours sufficient to lessen noise for lunch and dinner patrons and restaurant employees are agreed to by the City and all affected adjacent restaurant operators. 3. To the extent possible utilize a vibratory pile driver instead of an impact pile driver. Shroud the pile driver head and engine with noise control blanket barriers. 4. Install a plywood or noise control blanket barrier between the Water Street staging area and the Water Street Bistro. The barrier shall be solid and 8 feet high. 5. Equip all internal combustion engine -driven equipment with intake and exhaust mufflers that are in good condition and appropriate for the equipment. 6. Locate stationary noise generating equipment as far as possible from sensitive receptors when sensitive receptors adjoin or are near a construction project area. 7. Utilize "quiet" air compressors and other stationary noise sources where technology exists. 8. Designate a "disturbance coordinator" who will be responsible for responding to any local complaints about construction noise. The disturbance coordinator shall determine the cause of the noise complaint (e.g., starting to early, bad muffler, etc.) and shall require that City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EAMS Proposed MND 0205511002 GHD 64 reasonable measures warranted to correct the problem be implemented. Conspicuously post a telephone number for the disturbance coordinator at the construction site and include it in the notice sent to neighbors regarding the construction schedule. Implementation of Mitigation Measure NO -2 will limit the hours of pile driving (identified as the highest noise emitting component of the construction), require the use of a noise control blanket and barrier (which would reduce noise from pile driving by 5 to 10 dBA), and use quieter equipment when available and where feasible. With the incorporation of these noise reduction measures, the noise impact resulting from Project construction would be less than significant. XILe and f) Exposure of People Residing or Working near an Airport or Private Airstrip to Excessive Noise Levels — No Impact The Project site is not located within two miles of a public airport, a public use airport, or a private airstrip. The nearest such facility is Petaluma Municipal Airport approximately 2.25 miles to the northeast on Washington Street. The Project site is also outside the airport's land use referral boundary. Therefore, the Project would not expose people residing or working in the Project area to excessive noise levels generated by aircraft activities. The Project would have no impact. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 65 XIII. Population and Housing Potentially Significant Impact/Effect Less than Significant with Mitigation Less Than Significant Impact No Impact Would the project: a) Induce substantial population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., X through extension of roads or other infrastructure)? b) Displace substantial numbers of existing housing, necessitating the construction of X replacement housing elsewhere? c) Displace substantial numbers of people, necessitating the construction of X replacement housing elsewhere? Xlll.a) Induce Substantial Population Growth Directly or Indirectly — No Impact The Project would rehabilitate the existing trestle structure so that the Trestle can be safely accessed by pedestrians and bicyclists. The Project would not result in the addition of new housing units or new jobs, therefore the Project would not result in substantial. population growth either directly or indirectly. No impact would occur. Xlll.b and c) Displace Substantial Numbers of Existing Housing or People — No Impact The Project site is an existing trestle structure on the Petaluma River waterfront, and the Project consists of the rehabilitation of the structure for public access. No existing housing or places of employment would be displaced. No impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 66 XIV. Public Services Potentially Significant Impact/Effect Less than Significant with 'Impact Mitigation Less than Significant No Impact a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Fire protection? X Police protection? X Schools? X Parks? X Other public facilities? X XIV.a) Substantial Adverse Physical Impacts Associated with New or Physically Altered Governmental Facilities — No Impact The need for new governmental services is typically associated with the growth that comes from new residential or commercial development. The Trestle Project would rehabilitate an existing structure and does not involve any development associated with increasing service populations or an increased need for public services. No new public facilities would be needed to support operation of the Project. Therefore, the Project would have no impact on the service ratios, response times, or other performance objectives of schools, parks, and other public facilities that are based on population growth. No impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 67 XV. Recreation Potentially Significant Impact/Effect Less than Significant with Mitigation Less Than Significant No Impact a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that X substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or expansion of recreational facilities that might X have an adverse physical effect on the environment? XV.a) Increase in Use of Parks Resulting in Substantial Physical Deterioration — No Impact Similar to the discussion under Public Services, the increased use of existing recreational facilities is typically associated with the growth that comes from new residential or commercial development. The Trestle Project would rehabilitate an existing structure and does not involve any development associated with increasing service populations. The Project would not increase the use of parks, or similar facilities, resulting in substantial physical deterioration. No impact would occur. XV.b) Include Recreational Facilities that Might have Adverse Physical Impact on Environment — Less than Significant with Mitigation The Trestle Project could be considered a recreational facility. It is a place where people would gather for events, and walk and enjoy the views. However, the potential impacts related to implementation of the Project are analyzed in this EA/IS and where appropriate mitigation has been identified. Refer to Appendix A Mitigation Monitoring and Reporting Plan for a list of the Project mitigation. The Project would not have a significant adverse physical effect on the environment with incorporation of mitigation. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 68 XVI. Transportation/Traffic Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project: a) Conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non -motorized travel and X relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? b) Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other X standards established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels X or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g., sharp curves or X dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? X f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise X decrease the performance or safety of such facilities? XVI.a) Conflict with Applicable Plan, Ordinance, Policy, or Program Establishing Measures of Effectiveness for Performance of Circulation System — Less than Significant Construction of the Project would result in short-term increases in construction -related vehicle trips (estimated at the peak to be 13 trips per day for two weeks) on area roadways, including vehicle trips by construction workers, haul -truck trips associated with disposal of materials, and material and equipment deliveries. Access to the Project site may occur via a combination of regional roadways (Highway 101 and Lakeville Highway), local arterials (Lakeville Street, Petaluma Boulevard South, East Washington Street, and D Street), and collector streets (Water Street and C Street). City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EAMS Proposed MND 0205511002 GHD 69 Petaluma has established a level of service (LOS) standard of LOS D for City roadways. Table 3.2-5 of Petaluma's General Plan 2025 EIR (City of Petaluma 2008b) provides information on the LOS for multiple intersections along East Washington Street, Petaluma Boulevard South, and Lakeville Street extending from the Project area to the nearest regional highway (US 101). With the exception of Petaluma Boulevard South at D Street, each of the intersections in the Project area operates at levels of service that are in compliance with local standards. Petaluma Boulevard South at D Street is reported to operate unacceptably at LOS E during the PM peak hour. A project's contribution to an intersection operating at LOS E would be considered significant if it changed the LOS to F (City of Petaluma 2008a). A 55- to 79 -second delay is considered LOS E, and LOS F is an 80 -second or greater delay. Petaluma Boulevard South at D Street has a 57.1 -second delay during the PM peak. A portion of the Project's construction -related traffic may utilize this intersection at the end of the workday as construction workers leave the site. Other construction -related traffic would leave the staging area on the west side of the Trestle and would utilize Water Street to East Washington Street, Or would leave the staging area OR the east side Of the Trestle and weuid likely utilize the iRterseGtiOR fA- Rd D Street, a PGFtiGR Of Which weuld then head north OR D Street to rennert to Lakeville Street. However, the Project's contribution of construction traffic would be temporary and would not substantially affect the baseline traffic levels; therefore, the temporary impact from construction traffic along this roadway segment would be less than significant. Construction activities would not occur within the City right-of-way, and therefore would not require lane closures or cause an increase in traffic safety hazards from vehicles being routed into a travel lane adjacent to the work zone. Temporary construction impacts relative to the safety or performance of public transit, bicycle, or pedestrian facilities is evaluated under Impact XVI.f below. Following construction, operation of the Project would not result in new traffic that would cause congestion or that would affect the performance of the circulation system. In addition, operation of the Project would not introduce new users of alternative modes of transportation into the Project area, nor would it conflict with policies promoting bus turnouts, bicycle racks, pedestrian and bicycle paths, etc. Therefore, it would not cause a substantial increase in transit demand which cannot be accommodated by existing or proposed transit capacity or alternative travel modes. No operational impact would occur. XVI.b) Conflict with Applicable Congestion Management Program - No Impact The Sonoma County Transportation Authority (SCTA) is designated as the Congestion Management Agency for Sonoma County. The four stated goals of the 2009 Transportation Plan (SCTA 2009) are to maintain the system, relieve congestion, reduce emissions, and plan for safety and health. The Project would not conflict with these goals, given that the Project would not result in new long-term traffic that would cause additional congestion or emissions, and would not include any work within a local road or highway, and therefore would not affect public safety and health. No impact would occur. XVI.c) Result in a change in air traffic patterns - No Impact The Project has no components that would result in a change in air traffic patterns. No impact would occur. XVIA) Substantially Increase Hazards Due to Design Feature or Incompatible Uses - No Impact By design and intent, the Project would rehabilitate the Trestle to be a safe and functional part of the waterfront in accordance with local planning documents. The Project does not include any improvements City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 70 to a public roadway or any traffic-related design feature. Therefore, no impact relative to increased traffic hazards due to design features or incompatible uses would occur. XVI.e) Result in Inadequate Emergency Access — Less than Significant During construction, the Project's staging area west of the Trestle would be located behind a block of stores located on Petaluma Boulevard north of Western Avenue. The potential temporary impact on emergency access would be less than significant, given that the buildings would remain accessible from Petaluma Boulevard, which would be unobstructed by Project construction. In addition, pedestrian and emergency access would remain between the buildings and the staging area, from Western Street on the south to the alley on the north. The PrejeGt'-s staging area east Gf the Trestle weLild be !GGated ip a parking area adjaGent to the Petaluma YaGht Club. The potential tempeFary impaGt Gn ernergepGy-aGGess at this IGGatien would be less than significant, given that aGGess thFeugh the staging area would remaiR In addition, emergency access at the buildings located to the south of the Trestle would not be affected, as these buildings would remain accessible from surrounding streets unobstructed by the Project. None of the temporary access impairments during construction will prevent compliance with the General Plan standard set by Policy 7-P-19 of a 4-minute travel time for a total of a 6- minute response to emergencies. Following construction, operation of the Project would not result in inadequate emergency access because the Project would not result in any access obstructions. The impact is less than significant. XVI.f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease performance or safety of such facilities — Less than Significant Construction activities would not affect public transit or bicycle facilities because no such facilities exist in the area of construction. If the sta ire area to the west of the Trest,leisus�a g 9 ,Pedestrian access at the staging area would be maintained between the buildings and the staging area fence. The Balshaw Bridge pedestrian bridge would remain open during construction, and the pedestrian walkways around the existing Trestle would remain unobstructed during construction. The temporary impact on pedestrian facilities would therefore be less than significant. As summarized in Impact XVI.a above, operation of the Project would not introduce any new users of alternative modes of transportation into the Project area, nor would it conflict with policies promoting bus turnouts, bicycle racks, pedestrian and bicycle paths, etc. Implementation of the Trestle Project would once again open that portion of the River to pedestrian access overlooking the River. No operational impact would occur. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 71 XVII. Utilities and Service Systems Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant Impact No Impact Would the project: a) Exceed wastewater treatment requirements of the applicable Regional Water Quality X Control Board? b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the X construction of which could cause significant environmental effects? c) Require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of X which could cause significant environmental effects? d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded X entitlements needed? e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected X demand in addition to the provider's existing commitments? f) Be served by a landfill with sufficient permitted capacity to accommodate the X project's solid waste disposal needs? g) Comply with federal, state, and local statutes and regulations related to solid X waste? XVll.a, b, d, and e) Exceed Applicable Wastewater Treatment Requirements and Capacity, or Require Construction or Expansion of New Water or Wastewater Treatment Facilities — No Impact The Project would not create wastewater and therefore would not need to meet wastewater treatment requirements or need new or expanded wastewater treatment facilities. Construction of the Project is not expected to require the use of water; however, if needed, water use during construction would be minimal and temporary in duration, and would not require new or expanded water facilities. Operation of the Project would not use water and therefore would not require new or expanded water supply facilities. There would be no impact on water or wastewater treatment, capacity or facilities. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 72 XVll.c) Require Construction of New or Expansion of Existing Storm Water Drainage Facilities — No Impact The Project does not involve the construction of new storm water drainage facilities nor would such facilities be needed. The Project would rehabilitate an existing structure and would not create new impervious surfaces or facilities that would require storm drains. There would be no impact related to storm water drainage facilities. XVll.f and g) Have Sufficient Landfill Capacity and Comply with Statutes Related to Solid Waste — Less than Significant During construction, there would be a temporary small increase in solid waste disposal needs associated with construction debris. Much of the construction debris would consist of components of the existing trestle structure that have been treated with creosote. As discussed in Section Vlll.a.b, Mitigation Measure HM -1, Disposal of Treated Wood Waste, would be implemented to ensure compliance with DTSC management standards for the disposal of treated wood waste. In accordance with those standards the material would be taken to an approved facility of which there are several in the North Bay including Recology Hay Road Landfill which has a 70 -year life span, Kelly Canyon Landfill, and Clover Flat Landfill (DTSC accessed website 2012). Non hazardous solid waste would be minimal. Operation of the Project would not create solid waste. The impact to landfill capacity would be less than significant. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 73 XVlll.a and c) Less than Significant with Mitigation With implementation of the mitigation measures presented herein, the Project does not have the potential to degrade the quality of the environment, including fish or wildlife species or their habitat, plant or animal communities, important examples of the major periods of California history or prehistory, or cause substantial adverse effects on human beings. XVlll.b) Less than Significant Cumulative impacts are defined as "two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts" (CEQA Guidelines Section 15355). Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. This EA and IS/Proposed MND utilizes the "plan approach, per CEQA Guidelines Section 15130(d), to determine if the Project as a whole makes a considerable contribution to a significant cumulative impact. No reasonably foreseeable development or public works projects have been identified that could cause cumulative impacts. Therefore, the "plan approach" was used instead of the "list approach" because the evaluation would tend to identifv additional cumulative impacts. Cumulative impacts have been identified using the summary of projections contained in the Petaluma City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 74 Potentially Significant Impact/Effect Less than Significant with Mitigation Less than Significant No Impact XVIII. Mandatory Findings of Significance 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 X 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? b) Does the project have impacts which are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when X viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? c) Does the project have environmental effects that would cause substantial X adverse effects on human beings, either directly or indirectly? XVlll.a and c) Less than Significant with Mitigation With implementation of the mitigation measures presented herein, the Project does not have the potential to degrade the quality of the environment, including fish or wildlife species or their habitat, plant or animal communities, important examples of the major periods of California history or prehistory, or cause substantial adverse effects on human beings. XVlll.b) Less than Significant Cumulative impacts are defined as "two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts" (CEQA Guidelines Section 15355). Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. This EA and IS/Proposed MND utilizes the "plan approach, per CEQA Guidelines Section 15130(d), to determine if the Project as a whole makes a considerable contribution to a significant cumulative impact. No reasonably foreseeable development or public works projects have been identified that could cause cumulative impacts. Therefore, the "plan approach" was used instead of the "list approach" because the evaluation would tend to identifv additional cumulative impacts. Cumulative impacts have been identified using the summary of projections contained in the Petaluma City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EMS Proposed MND 0205511002 GHD 74 General Plan 2025 EIR (Petaluma 2008b). For this purpose, the General Plan EIR is incorporated by reference; it is available for review at the Petaluma City Hall at 11 English Street in Petaluma; and its State Clearinghouse number is 2004082065. The Trestle Project is specifically identified in General Plan 2025. Under Policy 2-P-3, Maintain Landmarks and Aspects of Petaluma's Heritage that Foster its Unique Identity, the Petaluma Trestle is listed under "adaptively reutilizing, reusing and preserving." Under Policy 2-P-11, Encourage and Support the Rehabilitation ... of Structures Reflective of the History of Petaluma's... Past, the Trestle is also listed. The General Plan 2025 EIR identified significant cumulative impacts related to greenhouse gas (GHG) emissions, and increased traffic levels as they relate to noise and level of service standards being exceeded at 6 intersections. These cumulative impacts are summarized in more detail below. The General Plan 2025 EIR found that while implementation of the Draft General Plan 2025 would not increase greenhouse gases over pre -project conditions, the cumulatively considerable incremental contribution of the General Plan 2025 as a whole on global climate change is significant and unavoidable. However, as noted in section VII Greenhouse Gas Emissions of this EA/Proposed IS -MND, given the short construction period (five months) and the inclusion of Basic Construction Measures in the project design, the impact to GHG emissions during construction would be less than significant. For operation, nighttime lighting would generate a negligible amount of indirect GHG emissions from electricity use. Thus, the Trestle Project would not increase community -wide greenhouse gas levels that exceed pre - project levels by a substantial margin, and therefore would not result in a cumulatively considerable incremental contribution to the cumulative impact of global climate change. The General Plan 2025 EIR identified significant unavoidable traffic impacts at six intersections. Two of these intersections are within the vicinity of the Project site and could potentially be used by construction related traffic (Lakeville Street/East D Street and Petaluma Boulevard South/D Street). However, given the small number of construction trips estimated (8 trips per day) and the small construction timeframe (5 months), the Project's temporary contribution to the cumulative impact at these intersections would not be considerable. Finally, significant traffic noise impacts were identified for Ely Road north of Frates Road and Frates Road east of Ely Road. However, these roadway segments are on the east side of Petaluma and would not be used by Project construction -related traffic. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 75 2.2 Other Required Analysis for NEPA Environmental Justice — No Impact Executive Order 12898 (EO 12898) requires federal agencies to identify and address adverse human health or environmental effects of federal programs, policies, and activities on minority and low-income populations. Enacted in 1994, EO 12898 directs each Federal agency to make environmental justice part of its mission. Federal agencies must identify and address the human health or environmental effects of its actions on minority and low-income populations through this EO. Criteria used for determining the significance of socioeconomic and environmental justice impacts are based on EO 12898 and CEQ's NEPA regulations. Impacts were considered significant if the Proposed Action would: • Change local employment opportunities in a manner that would disproportionately affect minority or low-income populations; or • Disproportionately affect minority communities or low-income communities through exposure to human health or environmental hazards. The Proposed Action would employ workers during construction. The Trestle Project is comparatively small and would likely employ local workers and not require new workers to move to the Petaluma area. Once constructed, the Proposed Action would not generate new permanent jobs. Neither construction nor operation of the Proposed Action would have a potential employment impact on the labor market. Additionally, neither construction nor operation of the Proposed Action would involve the displacement of existing employment -generating businesses or the establishment of new employment -generating businesses. As no employment impacts would occur, no impact to minority or low-income populations would occur. The U.S. EPA's guidelines for incorporating environmental justice concerns into NEPA analyses identify an area with a minority population as one where the minority population constitutes more than 50% of the area's total population, or is "meaningfully greater" than the percentage in the surrounding region. A minority is defined as referring to the following population groups: American Indian/Alaskan Native, Asian or Pacific Islander, Black (non -Hispanic), and Hispanic (U.S. EPA 1998). The U.S. EPA identifies an area as low-income if the low-income population is more than 50% of the area's total population, or is "meaningfully greater" than the percentage of low-income residents in the surrounding region. Low- income refers to households with an income below the federal poverty level (U.S. EPA 1998). As guided by the above criteria, this section uses demographic data for the City of Petaluma to assess potential impacts to environmental justice. The demographic characteristics of the City of Petaluma from the 2010 Census indicate a predominantly White population (80%) (U.S. Census Bureau 2010). The Proposed Action would not be located in a high minority or low-income census tract area. The Trestle is surrounded by commercial development, consisting of restaurants and shops, to the south, east and west. The Proposed Action would not exclude, deny, or subject persons to discrimination as environmental effects would not be located in a high minority or low-income census tract area. No impact would occur. Floodplain Management Refer to IX Hydrology and Water Quality for a discussion of the 100 -year floodplain. Protection of Wetlands City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 76 Refer to IV Biological Resources for a discussion on the impact to wetlands. Energy Resources Construction of the Proposed Action would require the use of fuels for a variety of construction activities and vehicle travel to and from the project site which would result in a temporary increase in energy use. However, construction would last for only five months and would be less intensive than traditional land use development that requires a larger fleet of earthmoving equipment or soil off -hauling and/or delivery and similar such equipment. In addition, as noted in the Project Description, applicable Basic Construction Measures would be included in the project design and implemented during construction. These measures include the following: 1) idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes; and 2) all construction equipment shall be maintained and properly tuned in accordance with manufacturer's specifications and checked by a certified visible emissions evaluator. Given the short construction period (five months) and the inclusion of Basic Construction Measures in the project design, energy use during project construction would be less than significant. The only energy that would be used during operation of the Proposed Action would be electricity for the nighttime lighting that may be installed for safety purposes. This impact to energy resources from operation of the Proposed Action is considered less than significant. Endangered Species Act Refer to IV Biological Resources for a discussion on the impact to special -status species, including those protected under the Endangered Species Act. Wild and Scenic Rivers Act The Petaluma River is not listed as a Wild and Scenic River (U.S. FWS n.d.) Noise Control Act The Proposed Action is anticipated to comply with the Noise Control Act. Refer to section XII Noise for a discussion on noise impacts and mitigation. Coastal Zone Management Act The site of the Proposed Action does not fall within a coastal zone, including Bay Conservation Development Commission jurisdiction. Protection of Historic and Cultural Properties Refer to V Cultural Resources for a discussion of the impacts and mitigation associated with historic and cultural properties. Economic A portion of the existinq boat dock would be closed at all times durinq construction of the Proposed Action, thus potentially decreasing local economic activity from visitors who dock their boats and visit local restaurants and retail shops. The dock is rarely fully occupied except on holiday weekends Construction would last for up to five months and would start after July 1 thus resulting in one major holiday weekend (Labor Day) that would be disrupted by project construction. The Contractor would leave as much of the dock open as feasible and safe; not all the dock in front of the Trestle would be closed at one time Because the berths at the existing docks are only partially occupied most of the time it is expected that City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 77 the berths that remain available during construction would accommodate most visitors who want to dock their boats in the Turninq Basin. During Labor Day weekend construction of the Proposed Action would likely prevent some visitors from docking in the Turning Basin and could therefore decrease economic activity over the holiday weekend. This effect on economic activity is short-term and limited and would therefore be less than significant. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EA/IS Proposed MND 0205511002 GHD 78 f 3. Preparers The following GHD team members contributed to the preparation of this EMS -Proposed MND. Kristine Gaspar Senior Planner Craig Lewis Project Engineer Carol Kielusiak Senior Planner Brian Bacciarini Senior Scientist Chelsea Phlegar Planner Special Reports Illingworth & Rodkin - Noise WRA — Biological Resources City of Petaluma Trestle Rehabilitation Project Recirculated EMS Proposed MND GHD August 2012 0205511002 79 4. Source References Association of Bay Area Governments (ABAG). 2003. Interactive WUI Fire Threat Map. Accessed April 25, 2012 online at.http://quake.abag,ca,gov/wildfires/ Bay Area Air Quality Management District (BAAQMD). 2012. Air Quality Standards and Attainment Status. http://hank.baagmd.gov/pin/air quality/ambient air quality htm Accessed website on April 23, 2012. BAAQMD. 2011. California Environmental Quality Act Air Quality Guidelines. May BAAQMD. 2011. Recommended Methods for Screening and Modeling Local Risks and Hazards. May. BAAQMD. 2010. Screening Tables for Air Toxic Evaluation during Construction. May California Department of Conservation. 2009, Sonoma County Williamson Act Lands 2008. California Department of Conservation. 2010. Sonoma County Important Farmland 2008. California Department of Fish & Game. 2012. Letter to City of Petaluma regarding Trestle Rehabilitation Project. July 6. California Department of Toxic Substances Control. List of RWQCB Certified Treated Wood Waste Landfills. Accessed website on May 25, 2012: http://www.dtsc.ca.gov/HazardousWaste/upload/TWW Confirmed_Landfill_List.pdf California Department of Toxic Substances Control. 2008. Fact Sheet: Requirements for Generators of Treated Wood Waste (TWW). December. California Water Resources Control Board. 2010. Final California 2010 Integrated Report (303(4) List/305(b) Report) Chattan, Cassandra. 2002. A Preliminary Evaluation for Cultural Resources Along Water Street in Petaluma, Sonoma County, Archaeological Resources Service. October 30, Chattan, Cassandra. 2003a. An Evaluation of Cultural Resources Along the Proposed Petaluma Trolley Master Plan Project. Archaeological Resource Service. March 21. Chattan, Cassandra. 2003b. A Preliminary Evaluation for Cultural Resources along the Proposed Petaluma River Walk, Petaluma, Sonoma County. March 11. Chattan, Cassandra. 2004. A Cultural Resources Evaluation of the Petaluma Trestle Renovation Alternatives, on the Petaluma River, Petaluma, Sonoma County, California. Archaeological Resource Service. November 2. City of Petaluma. 2008a. City of Petaluma: General Plan 2025. (Revised 2012). City of Petaluma. 2008b. City of Petaluma: General Plan 2025 EIR. City of Petaluma. 2008c. Bicycle and Pedestrian Plan. May. City of Petaluma. 2003. Central Petaluma Specific Plan. June 2. City of Petaluma. 2003. McNear Peninsula Shoreline Trail and Riverine Improvements Initial Study and Mitigated Negative Declaration. City of Petaluma. 2002. Water Recycling Facility and River Access Improvements EIR April 2002 City of Petaluma. 1996. Petaluma River Access and Enhancement Plan. May. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 80 Cohen, A.N., D.R. Calder, J.T. Carlton, J.W. Chapman L.H. Harris T. Kitayama C.C. Lambert G.Lambert, C. Piotrowski, M. Shouse and L.A. Solorzano. 2005. Rapid Assessment Shore Survey for Exotic Species in San Francisco Bay. Final Report for the California State Coastal Conservancy. Association of Bay Area Governments/San Francisco Bay -Delta Science Consortium, National Geographic Society and Rose Foundation San Francisco Estuary Institute Oakland, CA. Davis, David D. 2011. Letter from David D. Davis, Winzler & Kelly, to Debbie Treadway, Native American Heritage Commission, regarding Sacred Lands & Native American Contacts List Request, Petaluma Trestle Rehabilitation Project, Petaluma, CA. August 30. Flynn & Associations, Inc. 2011. City of Petaluma Trestle Rehabilitation. October 14. Illingworth & Rodkin. 2012a. Trestle Rehabilitation Environmental Noise Assessment. April 27. Illingworth & Rodkin. 2012b. Trestle Rehabilitation Project Underwater Sound Levels from Pile Driving. May 3. Illingworth & Rodkin. 2012c. Underwater Sound Levels from Pile Driving. May 7. Miller Pacific Engineering Group. 2011. Geotechnical Investigation - Petaluma Trestle Rehabilitation. November 30. National Marine Fisheries Service, Joseph Dillon. Personal Communication, email and phone. February 17 and 21, 2012. National Oceanic and Atmospheric Administration (NOAA). 2009. National Marine Fisheries Service Biological Opinion for Marin Sonoma Highway 101 Narrows Project. File No 2007/08320:DHW National Marine Fisheries Service, Long Beach, CA. Oggins, Cy. R. 2012. Letter from CV. R. Oggins, California State Lands Commission to Diane Ramirez City of Petaluma, regarding Environmental Assessment/Initial Study/Mitigated Negative Declaration (EA/IS/MND) for the Trestle Rehabilitation Project Petaluma River Sonoma County. July 11 PAST Consultants. 2007. Petaluma & Santa Rosa Railroad Trestle, Petaluma, California, Historic Structure Report. Prepared by PAST Consultants, LLC and Creegan &+ D'Angelo Engineers. Prepared for City of Petaluma. November 30. Preservation Architecture, 2011. The Petaluma Trestle Historic Resource Evaluation. October 7. Preservation Architecture. 2012. The Petaluma Trestle Standards Evaluation. April 9. Roop, William. 2003. An Archaeological Evaluation of the Proposed Petaluma Town Center Project, Petaluma, Sonoma County, California. Sanchez, Katy. 2011. Letter from Katy Sanchez, Native American Heritage Commission, to David D. Davis, Winzler & Kelly, regarding Proposed Petaluma Trestle Rehabilitation Project, Sonoma County. September 8. Sonoma County. 1998. General Plan. Sonoma County Permit and Resource Management Department. 2001. Comprehensive Airport Land Use Plan for Sonoma County. http://www.sonoma-countV.org/prmd/docs/airporUch8-excerpt.htm January, amended in October 2001. Accessed website on April 27, 2012. Sonoma County Transportation Authority. 2009. Comprehensive Transportation Plan for Sonoma County. October 19. State Water Resources Control Board: GeoTracker. 2012. http://geotracker.waterboards.ca.gov/map/?CMD=runreport&mvaddress=water+street%2C+petalu ma%2C+ca. Accessed website on April 26. City of Petaluma Trestle Rehabilitation Project August 2012 Recirculated EARS Proposed MND 0205511002 GHD 81 r Stratus Consulting. 2006. Creosote -Treated Wood in Aquatic Environments: Technical Review and Use Recommendations. December 31. Tipon, Nick. 2011. Letter from Nick Tipon, Federated Indians of Graton Rancheria, to David Davis, Winzler & Kelly, regarding Petaluma Trestle Rehabilitation Project. October 4. U.S. Census Bureau. 2010. 2010 Census Interactive Population Search, Petaluma City. http://2010 census qov/2010census/popmap/ipmtext php?fl-06 U.S. Environmental Protection Agency (U.S. EPA). 2012. The Green Book Nonattainment Areas for Criteria Pollutants. March 30. Accessed online on May 4, 2012 at http://www.epa. oy v/oagps001/qreenbk/index.htmi U.S. EPA. 1998. Final Guidance for Incorporating Environmental Justice Concerns in EPA's NEPA Compliance Analyses. Washington, DC: U.S. Government Printing Office. U.S. Fish and Wildlife Service (U.S. FWS). n.d. http://www.rivers.qov/wiIdriversIist.htm1. Accessed website on April, 27 2012. USGS. Mineral Resources Data System On -Line Spatial Data Accessed July 24 2012 online at http://tin.er.usgs.gov/mrds/find-mrds.phr) US. Geological Survey (USGS). 1998. Open -File Report 97-745C. San Francisco Bay Region Landslide Folio Part C. Summary Distribution of Slides and Earth Flows in the San Francisco Bay Region, California. C.M. Wentworth et. al., Revision 1 February 17. USGS. 2006. Liquefaction Susceptibility Map. Based on work by William Lettis & Associates, Inc., USGS Open -File Report 00-444, Knudsen & others, 2000 and USGS Open -File Report 2006-1037, Witter & others. Winzler & Kelly. 2011 a. Draft Conceptual Design for Rehabilitation of Petaluma Trestle. November 23. Winzler & Kelly. 2011b. 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T3m2o m a o e« o o% CL c c /§\\\ n«0tmƒr- k�o 5® E ID /E a/S£moee eaq :3 E a) e3 r -C:_°_'§§ ƒ \\: = omo 77'E}/G@oo �o eme moem « -1 in 5a Oma�Ec) \ a K a / B Appendix B Jurisdictional and Habitat Maps Study Area Culverts High Tide Line (CORPS of Engineers Section 404) Top of Bank (RWQCB, CDFG) r S4 Path: L:1Acad 2000 Files\19000119047-2\GISWrcMap\Preliminary_Delineation.mxd ENVIRONMENTAL CONSULTANTS Petaluma Trestle Rehabilitation Project Sonoma County, California Regulatory Agency Jurisdictional Delineation Map N NV+E S 0 25 50 100 Feet Map Date: August 2011 Map By: Michael Rochelle rg3 9 � , x c SE"T t m _o �^ 0 c O � C O � fr ' N :p. •O .�' Q C N r C � W o o U_ O •E O U = � cu W c J �. co co > co: p "o1=1 =3 75 (A U Q p c O °i L- �1 1 # z �y rn LO m + E (0 E ro m D $ m " c U N > > - wow O °- N 0 u h y - .. <.. • ,, z; bra ? L�_; 3, ,� �mx"'�� rg3 9 � , x c SE"T t m _o �^ 0 c O � C O � U)Op C W r C � W O O Q o U_ fl. O U = � cu W c J �. co co > Z =3 75 (A U 5 _ ++ �1 1 # rn LO ...� + ,s-. is rg3 9 � , x c SE"T t m Appendix C npai::11-Ctatu Cniza Biological Resource Assessment 771 Alk Ah OF Petaluma Trestle Rehabilitation Project PETALUMA, SONOMA COUNTY, CALIFORNIA Prepared For: GHD 2235 Mercury Way, Suite 150 Santa Rosa, CA 95407 WRA Contact: Doug Spicher spicher@wra-ca.com Date: May 9, 2012 Revised July 25, 2012 wra ENVIRONMENTAL CONSULTANTS 2169-G East Francisco Blvd„ San Rafael, CA 94901 (415) 454-8868 lei (415) 454-0129 fax info@wra-co,com www.wra•ca.com TABLE OF CONTENTS Listof Abbreviated Terms............................................................................................................. ii 1.0 INTRODUCTION............................................................................................................... 1 2.0 REGULATORY BACKGROUND....................................................................................... 2 2.1 Special Status Species................................................................................................ 2 2.2 Sensitive Biological Communities................................................................................ 3 3.0 METHODS......................................................................................................................... 4 3.1 Biological Communities............................................................................................... 4 3.1.1 Non -sensitive Biological Communities............................................................... 5 3.1.2 Sensitive Biological Communities....................................................................... 5 3.2 Special Status Species................................................................................................ 6 3.2.1 Literature Review................................................................................................ 6 3.2.2 Site Assessment................................................................................................. 6 4.0 RESULTS.......................................................................................................................... 7 4.1 Biological Communities............................................................................................... 7 4.1.1 Non -sensitive Biological Communities................................................................8 4.1.2 Sensitive Biological Communities.....................................................................9 4.2 Special Status Species.............................................................................................. 10 4.2.1 Plants............................................................................................................... 10 4.2.2 Wildlife............................................................................................................. 10 5.0 SUMMARY AND EVALUATION OF POTENTIAL IMPACTS............................................13 5.1 Biological Communities.............................................................................................13 5.1.1 Potential Impacts................................................................................................13 5.1.2 Mitigation Measures..........................................................................................14 5.2 Special Status Plant Species..................................................................................... 15 5.3 Special Status Wildlife Species................................................................................. 15 5.3.1 Potential Impacts................................................................................................15 5.3.2 Mitigation Measures............................................................................................16 5.4 Migratory Birds, ....................................................................................... ........................ 17 6.0 REFERENCES................................................................................................................ 18 LIST OF FIGURES Figure 1. Project Area Location Map Figure 2. Project Site Plan Figure 3. Biological Communities Map Fiugre 4. Jurisdictional Delineation Map LIST OF TABLES Table 1. Biological Communities within the Project Area............................................................ 8 LIST OF APPENDICES Appendix A- Plant Species Observed in the Project Area Appendix B- Potential for Special Status Plant and Wildlife Species to Occur in the Project Area Appendix C- Representative Project Area Photographs 9 List of Abbreviated Terms ACOE Army Corps of Engineers BRA Biological Resources Assessment BMP Best Management Practices CCR California Code of Regulations CDFG California Department of Fish and Game CESA California Endangered Species Act CEQA California Environmental Quality Act CNDDB California Natural Diversity Data Base CNPS California Native Plant Society CRLF California Red -legged Frog ESA Endangered Species Act FAC Facultative plant (equally likely to occur in wetlands and non - wetlands) FACU Facultative upland plant (67-99% probability in non wetlands) FACW Facultative wetland plant (Estimated 67-99% probability of occurrence in wetlands) NEPA National Environmental Policy Act NGVD National Geodetic Vertical Datum NLAA Not Likely to Adversely Affect NMFS National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration RWQCB Regional Water Quality Control Board USFWS United States Fish and Wildlife Service USGS United States Geological Survey ii 1.0 INTRODUCTION In response to comment letters received from California Department of Fish and Game (CDFG) and California State Lands Commission (SLC) concerning the proposed IS/MND for this project, this Biological Resources Assessment Report has been revised. Additions are shown in bold and underline and information that has been eliminated is crossed -through. On August 2, 2011, WRA, Inc. performed an assessment of biological resources at the Petaluma Trestle along the Petaluma River in downtown Petaluma, Sonoma County, California (Figure 1). The Project Area is located in downtown Petaluma along the Petaluma River between Water Street and B Street. The purpose of the assessment was to gather information necessary to complete a review of biological resources under the California Environmental Quality Act (CEQA) and regulatory permitting. The Project Area, for assessment purposes, is comprised of the historic railroad trestle that will be rehabilitated and the adjacent bank along the south-western side of the Petaluma River in downtown Petaluma from 1" Street and to Water Street and the eastern bank where the existing floating dock along the trestle will be temporarily located during trestle construction. Surrounding the Project Area are developed structures, including a former old mill building now housing restaurants and retail stores, streets, and parking areas. This report assesses the Project Area for: (1) presence of special -status species; (2) potential to support special -status species; and (3) presence of other sensitive biological resources protected by local, state, and federal laws and regulations. The proposed project is a rehabilitation of the historic trestle structure that will support the economic revitalization of downtown Petaluma and remove a public hazard. Rehabilitation is expected to include the following elements (Figure 2): 1. Replacement, repair, and preservation of wooden trestle decking and cross support structures (portions of trestle that are generally above water). 2. Replacement, repair, and preservation of wooden piles that support the trestle deck, including wrapping piles that can be preserved in place and use of steel pipes to "jacket" and/or create splices of existing piles. Some extremely deteriorated piles may need to be replaced entirely with new wooden piles (treated with ACZA). It is estimated that this work would increase the amount of area covered by piles by approximately 192 square feet in waters and mudflat habitat. Installation of steel jackets or new piles may be by vibratory or impact hammer. 3. Temporary re -location of the existing floating dock along the trestle to the opposite shore. 4. Construction of an approximately 50 to 75 -foot long retaining wall to support a failing portion of riverbank. One of two methods to construct the structure would be used, either a vertical H - pile structure or use of steel, vinyl, or FRP sheet piles. Installation would be by rotary drilling holes (for H -pile structure) or "press -in" hydraulic or vibratory hammer for sheet piles. 5. Extension of the trestle deck to create a pedestrian walkway along the existing trestle to the existing concrete walkway on the shore. The new deck would vary from approximately 10 feet to 30 feet wide and would be approximately 200 feet long. 1 Most of the work on the trestle will be conducted from barges on the water, however work on the retaining wall and trestle deck extension will be from land adjacent to the trestle. A biological assessment provides general information on the potential presence of sensitive species and habitats. The biological assessment is not an official protocol level survey for listed species that may be required for project approval by local, state, or federal agencies. However, specific findings on the occurrence of any species or the presence of sensitive habitats may require that protocol surveys be conducted. This assessment is based on information available at the time of the study and on site conditions that were observed on the date of the site visit. 2.0 REGULATORY BACKGROUND The following sections explain the regulatory context of the biological assessment, including applicable laws and regulations that were applied to the field investigations and analysis of potential project impacts. 2.1 Special Status Species Special -status species include those plants and wildlife species that have been formally listed, are proposed as endangered or threatened, or are candidates for such listing under the federal Endangered Species Act (ESA) or California Endangered Species Act (CESA). These Acts afford protection to both listed and proposed species. In addition, California Department of Fish and Game (CDFG) Species of Special Concern, U.S. Fish and Wildlife Service (USFWS) Birds of Conservation Concern, sensitive species included in USFWS Recovery Plans, and CDFG special status invertebrates are all considered special -status species. Although CDFG Species of Special Concern generally have no special legal status, they are given special consideration under the California Environmental Quality Act (CEQA). In addition to regulations for special -status species, most birds in the United States, including non -status species, are protected by the Migratory Bird Treaty Act of 1918. Destroying active nests, eggs, and young is illegal under this legislation. Plant species on California Native Plant Society (CNPS) Lists 1 and 2 are also considered special status plant species, and impacts to these species are considered significant according to CEQA. CNPS List 3 plants are not required to be reviewed under CEQA, but are included in this analysis for completeness. Critical Habitat Critical habitat is a term defined and used in the Federal Endangered Species Act as a specific geographic area that contains features essential for the conservation of a threatened or endangered species and that may require special management and protection. The FESA requires federal agencies to consult with the USFWS to conserve listed species on their lands and to ensure that any activities or projects they fund, authorize, or carry out will not jeopardize the survival of a threatened or endangered species. In consultation for those species with critical habitat, federal agencies must also ensure that their activities or projects do not adversely modify critical habitat to the point that it will no longer aid in the species' recovery. In many cases, this level of protection is similar to that already provided to species by the FESA "jeopardy standard." However, areas that are currently unoccupied by the species but which are needed for the species' recovery, are protected by the prohibition against adverse modification of critical habitat. 4 2.2 Sensitive Biological Communities Sensitive biological communities include habitats that fulfill special functions or have special values, such as wetlands, streams, and riparian habitat. These habitats are regulated under federal regulations (such as the Clean Water Act), state regulations (such as the Porter - Cologne Act and the California State Fish and Game Code), or local ordinances or policies (City or County Tree Ordinances, Special Habitat Management Areas, and General Plan Elements). Waters of the United States The U.S. Army Corps of Engineers (Corps) regulates "Waters of the United States" under Section 404 of the Clean Water Act. "Waters of the U.S." are defined broadly as waters susceptible to use in commerce, including interstate waters and wetlands, all other waters (intrastate waterbodies, including wetlands), and their tributaries (33 CFR 328.3). Potential wetland areas, according to the three criteria used to delineate wetlands stated in the Corps of Engineers Wetlands Delineation Manual (1987), are identified by the presence of (1) hydrophytic vegetation, (2) hydric soils, and (3) wetland hydrology. Areas that are inundated for sufficient duration and depth to exclude growth of hydrophytic vegetation are subject to Section 404 jurisdiction as "other waters" and are often characterized by an ordinary high water line (OHW). Other waters, for example, generally include lakes, rivers, and streams. The placement of fill material into "Waters of the U.S." (including wetlands) generally requires an individual or nationwide permit from the Corps under Section 404 of the Clean Water Act. Waters of the State The term "Waters of the State" is defined by the Porter -Cologne Act as "any surface water or groundwater, including saline waters, within the boundaries of the state." The Regional Water Quality Control Board (RWQCB) protects all waters in its regulatory scope, but has special responsibility for wetlands, riparian areas, and headwaters. These waterbodies have high resource value, are vulnerable to filling, and are not systematically protected by other programs. RWQCB jurisdiction includes "isolated" wetlands and waters that may not be regulated by the Corps under Section 404. "Waters of the State" are regulated by the RWQCB under the State Water Quality Certification Program which regulates discharges of fill and dredged material under Section 401 of the Clean Water Act and the Porter -Cologne Water Quality Control Act. Projects that require a Corps permit, or fall under other federal jurisdiction, and have the potential to impact "Waters of the State," are required to comply with the terms of the Water Quality Certification determination. If a proposed project does not require a federal permit, but does involve dredge or fill activities that may result in a discharge to "Waters of the State," the RWQCB has the option to regulate the dredge and fill activities under its state authority in the form of Waste Discharge Requirements or Certification of Waste Discharge Requirements. Streams, Lakes, and Riparian Habitat Streams and lakes, as habitat for fish and wildlife species, are subject to jurisdiction by CDFG under Sections 1600-1616 of the State Fish and Game Code. Alterations to or work within or adjacent to streambeds or lakes generally require a 1602 Lake and Streambed Alteration Agreement. The term stream, which includes creeks and rivers, is defined in the California Code of Regulations (CCR) as follows: "a body of water that flows at least periodically or 3 intermittently through a bed or channel having banks and supports fish or other aquatic life. This includes watercourses having a surface or subsurface flow that supports or has supported riparian" vegetation" (14 CCR 1.72). In addition, the term stream can include ephemeral streams, dry washes, watercourses with subsurface flows, canals, aqueducts, irrigation ditches, and other means of water conveyance if they support aquatic life, riparian vegetation, or stream - dependent terrestrial wildlife (CDFG ESD 1994). Riparian is defined as, "on, or pertaining to, the banks of a stream;" therefore, riparian vegetation is defined as, "vegetation which occurs in and/or adjacent to a stream and is dependent on, and occurs because of, the stream itself' (CDFG ESD 1994). Removal of riparian vegetation also requires a Section 1602 Lake and Streambed Alteration Agreement from CDFG. Other Sensitive Biological Communities Other sensitive biological communities not discussed above include habitats that fulfill special functions or have special values. Natural communities considered sensitive are those identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game (CDFG). CDFG ranks sensitive communities as "threatened" or "very threatened" and keeps records of their occurrences in its Natural Diversity Database. Sensitive plant communities are also identified by CDFG on their List of California Natural Communities Recognized by the CNDDB. Impacts to sensitive natural communities identified in local or regional plans, policies, regulations or by the CDFG or USFWS must be considered and evaluated under CEQA (California Code of Regulations: Title 14, Div. 6, Chap. 3, Appendix G). Specific habitats may also be identified as sensitive in City or County General Plans or ordinances. Relevant Local Policies, Ordinances, Regulations Chapter 8.28 of the City of Petaluma's Municipal Code defines Heritage and Landmark trees that may be protected. Heritage trees are defined as native species of historic, cultural or environmental significance to the community or commemorative plantings by a group of citizens or the city in recognition of a significant community member or event. Landmark Trees are defined as trees that are of exceptional size or age as relates to generally accepted horticultural standards for the species, trees with unusual or distinctive form, character, function or visual impact as related to the species and setting, or trees associated with a historically significant person, structure, or event. Trees do not automatically become Heritage or Landmark trees if they meet the criteria. Instead, trees must be nominated for designation as one of these types by the landowner if on private land, or by the director, if on public land. 3.0 METHODS On August 2, 2011 the Project Area was traversed on foot to determine: (1) plant communities present within the Project Area, (2) if existing conditions provided suitable habitat for any special -status plant or wildlife species, and (3) if sensitive habitats are present. 3.1 Biological Communities Prior to the site visit, the Soil Survey of Sonoma County, California [U.S. Department of Agriculture (USDA) 1972], the USGS 7.5 minute Petaluma quadrangle, and available aerial 0 photographs were examined to determine if any unique soil types that could support sensitive plant communities and/or aquatic features were present in the Project Area. Biological communities present in the Project Area were classified based on existing plant community descriptions described in the Preliminary Descriptions of the Terrestrial Natural Communities of California (Holland 1986). However, in some cases it is necessary to identify variants of community types or to describe non -vegetated areas that are not described in the literature. Biological communities were classified as sensitive or non -sensitive as defined by CEQA and other applicable laws and regulations. 3.9.1 Non -sensitive Biological Communities Non -sensitive biological communities are those communities that are not afforded special protection under CEQA, and other state, federal, and local laws, regulations and ordinances. These communities may, however, provide suitable habitat for some special status plant or wildlife species and are identified or described below. 3.1.2 Sensitive Biological Communities i Sensitive biological communities are defined as those communities that are given special protection under CEQA and other applicable federal, state, and local laws, regulations and ordinances. Applicable laws and ordinances are discussed above in Section 2.0. Special methods used to identify sensitive biological communities are discussed below. Wetlands and Waters The Project Area was surveyed to determine if any wetlands and waters potentially subject to jurisdiction by the Corps, RWQCB, or CDFG were present. The assessment was based primarily on the presence of wetland plant indicators, but also includes any observed indicators of wetland hydrology or wetland soils. Any potential wetland areas were identified as areas dominated by plant species with a wetland indicator status' of OBL, FACW, or FAC as given on the U.S. Fish and Wildlife Service List of Plant Species that Occur in Wetlands (Reed 1988). Evidence of wetland hydrology can include direct evidence (primary indicators), such as visible inundation or saturation, surface sediment deposits, algal mats and drift lines, or indirect indicators (secondary indicators), such as oxidized root channels. Some indicators of wetland soils include dark colored soils, soils with a sulfidic odor, and soils that contain redoximorphic features as defined by the Corps Manual (Environmental Laboratory, 1987) and Field Indicators of Hydric Soils in the United States (NRCS, 2002). The preliminary waters assessment was based primarily on the presence of unvegetated, ponded areas or flowing water, or evidence indicating their presence such as a high water mark or a defined drainage course. eollection of additional data will be necessary to prepare a delineation report suitable for submission to . The Corps of Engineers approved a section 404 jurisdictional determination on March 9, 2012. 1 OBL = Obligate, always found in wetlands (> 99% frequency of occurrence); FACW = Facultative wetland, usually found in wetlands (67-99% frequency of occurrence); FAC = Facultative, equal occurrence in wetland or non -wetlands (34-66% frequency of occurrence). 5 Other Sensitive Bioloaical Communities The Project Area was evaluated for the presence of other sensitive biological communities, including riparian areas, sensitive plant communities recognized by CDFG, and protected trees as defined by Chapter 8.28 of the City of Petaluma's Municipal Code. These sensitive biological communities were mapped and are described in the Section 4.1.2 below. 3.2 Special Status Species 3.2.1 Literature Review Potential occurrence of special status species in the Project Area was evaluated by first determining which special status species occur in the vicinity of the Project Area through a literature and database search. Database searches for known occurrences of special status species focused on Sonoma County, as well as the Cotati 7.5 minute USGS quadrangle and the eight surrounding USGS quadrangles. The following sources were reviewed to determine which special status plant and wildlife species have been documented to occur in the vicinity of the Project Area: • California Natural Diversity Database records (CNDDB) (CDFG 2011) • USFWS quadrangle species lists (USFWS 2011) • CNPS Electronic Inventory records (CNPS 2011) • CDFG publication "California's Wildlife, Volumes 1 -III" (Zeiner et al. 1990) • CDFG publication "Amphibians and Reptile Species of Special Concern in California" (Jennings 1994) • A Field Guide to Western Reptiles and Amphibians (Stebbins, R.C. 2003) • University of California at Davis Information Center for the Environment Distribution Maps for Fishes in California (2008) • National Marine Fisheries Service Distribution Maps for California Salmonid Species (2008) • U.S. Fish and Wildlife Service Endangered and Threatened Wildlife and Plants; 12 -month Finding on a Petition to List the San Francisco Bay -Delta Population of the Longfin Smelt as Endangered or Threatened (USFWS 2012) • CDFG Status Report on Longfin Smelt (CDFG 2009) • NMFS Biological Opinion for Marin Sonoma Highway 101 High Occupancy Vehicle Lane Widening Project: Novato to Petaluma (NOAA 2009) 3.2.2 Site Assessment A site visit was made to the Project Area to search for suitable habitats for species identified in the literature review as occurring in the vicinity. The potential for each special status species to occur in the Project Area was then evaluated according to the following criteria: 1) No Potential. Habitat on and adjacent to the site is clearly unsuitable for the species requirements (foraging, breeding, cover, substrate, elevation, hydrology, plant community, site history, disturbance regime). 2) Unlikely. Few of the habitat components meeting the species requirements are present, and/or the majority of habitat on or adjacent to the site is unsuitable or of very poor quality. The species is not likely to be found on the site. 10 3) Moderate Potential. Some of the habitat components meeting the species requirements are present, and/or only some of the habitat on or adjacent to the site is unsuitable. The species has a moderate probability of being found on the site. +` 4) High Potential. All of the habitat components meeting the species requirements are present and/or most of the habitat on or adjacent to the site is suitable. The species has a high probability of being found on the site. 5) Present. Species was observed on the site or has been recorded (i.e. CNDDB, other reports) on the site recently. The site assessment is intended to identify the presence or absence of suitable habitat for each special status species known to occur in the vicinity in order to determine its potential to occur in the Project Area. The site visit does not constitute a protocol -level survey and is not intended to determine the actual presence or absence of a species; however, if a special status species is observed during the site visit, its presence is recorded and discussed. Appendix B presents the evaluation of potential for occurrence of each special status plant and wildlife species known to occur in the vicinity of the Project Area with their habitat requirements, potential for occurrence, and rationale for the classification based on criteria listed above. Recommendations for further surveys are made in Section 5.0 below for species with a moderate or high potential to occur in the Project Area. 4.0 RESULTS The Project Area is in downtown Petaluma along the southwestern bank of the Petaluma River between Water Street and 1" Street and the eastern bank across the river, and consists of an historic railroad trestle and adjacent riverbanks. The trestle is composed of wood planks and railings supported by wooden pilings and the river bank along the western portion is supported by various ages of concrete retaining walls. The trestle, particularly the deck, is presently dilapidated and closed to pedestrian traffic. Beneath the trestle is open water and/or mudflat, and on the open eastern portion of the river bank a fringe of salt/brackish marsh vegetation is present. Landscaped grass and ornamental shrubs occupy the upper bank in open areas. Inland from the trestle and river bank is dense urban development, parking areas, and roads. Elevations of the Project Area range from approximately 0-10 feet above sea level. The Petaluma River is actually a tidal slough connected to San Pablo Bay 16 miles to the south. The main slough channel passes through the extensive Petaluma Marsh Wildlife Area, the largest remaining natural tidal brackish marsh in California. The Petaluma River is dredged regularly to maintain shipping access. The following sections present the results and discussion of the. biological assessment within the Project Area. 4.1 Biological Communities Table 1 summarizes the area of each biological community type observed in the Project Area. Non -sensitive biological communities in the Project Area include ruderal habitat and ornamental vegetation. Two sensitive biological communities were found in the Project Area; coastal brackish marsh and waters. Descriptions for each biological community are given below. Figure 3 shows the location and extent of biological community vegetated habitats and waters. 7 Table 1. Biological Communities within the Project Area. Community Type Area (acres) Ruderal 0.37 Ornamental 0.35 Coastal Brackish Marsh 0.36 Vegetated Area Subtota (1.08) Waters 5.00 Total Biological Communities 6.08 4.9.1 Non -sensitive biological communities The margins of the Project Area above the high tide line support areas of landscaped ornamental vegetation and unmaintained areas of non-native plants typically considered to be ruderal habitat. Ruderal Habitat Although not described in the literature as a habitat type, ruderal habitat includes areas that have been partially developed and left fallow or otherwise have had past soil disturbance that has not been maintained. The Project Area supports approximately 0.37 acres of this habitat which is comprised of disturbed riverfront habitat fragments, some adjoining ornamental vegetation alongside parking lots or businesses. Plant species often observed in ruderal habitat include wild oat (Avena sp.), black mustard (Brassica nigra), chicory (Chicorium intybus), bull thistle (Cirsium vulgare), bindweed (Convolvulus arvensis), horseweed (Conyza canadensis), fennel (Foeniculum vulgare), common tarweed (Centromadia pungens), prickly lettuce (Lactuca serriola), and bur clover (Medicago polymorpha). Ornamental A small amount of landscaped/ornamental trees, shrubs and grasses occupy portions of the Project Area. Ornamental vegetation is not a community described in the literature as a habitat type, but in the Project Area it includes planted native trees, such as coast redwood (Sequoia sempervirons) and deer grass (Muhlenbergia rigens). Whether native or non-native, ornamental trees, shrubs, or dense grass can provide nesting and foraging habitat for some wildlife. Ordinance Trees Existing trees in the Project Area are believed to have been planted at various times as landscaping and do not qualify for heritage or landmark status, including those considered to be California native trees (silk tassel and redwood). 1.1 Invasive Species Human activities, such as construction or recreation, can introduce new non-native species that are considered to be highly invasive into an area. Invasive species can displace native species and change community (both aquatic and terrestrial) structure and functioning. Introductions can be in the form of live organisms or propagules often carried in on vehicles, on construction equipment, in discharged ship ballast, or other means in sufficient numbers and timing such that they are capable of colonization and reproduction. California State Lands Commission (SLC 2012) pointed out a specific example that can be especially damaging to aquatic environments, the quagga mussel, which has been spreading across the United States after being introduced into the Great Lakes by ship ballast water from Europe. Invasive species can also be introduced to a new area through natural distribution from distant occupied areas. An introduction of a non-native species documented in the Petaluma River includes an aquatic hydrozoan (Maeotias marginata), a jellyfish -like creature, thought to have been introduced into San Francisco Bay from Europe in ship ballast. This species probably gradually migrated up the Petaluma River from San Francisco Bay where conditions are suitable for its existence. Introductions of new invasive species in the aquatic habitat may not be easily controlled, however the most effective control of an invasive species is often by natural habitat conditions. In the case of the quagga, mussel, for example, the high salinity of the Petaluma River during the low flow period in summer would not allow this invasive mussel to become established. The quagga mussel can tolerate water salinity no higher than 4-5 parts per thousand (Benson, Richerson, Maynard, Larson, and Fusaro 2012) In summer the entire tidally influenced reach of the Petaluma River reaches 10 ppt salinity and higher (City of Petaluma 2002) and Cohen et. al. (2005) measured water salinity in the Project Area (Petaluma River Turning Basin) in late May 2004 to already be 8 ppt Therefore, even if introduced into the Petaluma River at the Project Area, quagga mussels would succumb to intolerable salinity. In addition, the relatively small size of the trestle project is likely to only attract local contractors (Sonoma County and around San Francisco Bay) that are not likely to be carrying new invasive species from distant locations that are not already established in r the Petaluma River. I New introductions of invasive vascular plants into the Project Area are not likely because of the relatively small area of high intertidal and uplands capable of being occupied by plants. The plant community presently is a mixture of native and non-native plants with dense cover, and establishment by a new species is unlikely. Areas temporarily disturbed during construction would likely be quickly re -colonized by re -growth of the plant species that are now present and/or by native plants installed for revegetation 4.1.2 Sensitive Biological Communities Two sensitive biological communities were observed within the Project Area: coastal brackish marsh and waters (the Petaluma River). Coastal brackish marsh occurs in sparse patches on the river bank alongside the trestle and on the eastern riverbank. Beneath the trestle is open water with areas of mudflat exposed at various stages of low tide. These habitats are described in more detail below. Waters The Petaluma River flows through the Project Area and is considered an "Other Waters" under the jurisdiction of the U.S. Army Corps of Engineers (Section 404 Clean Water Act up to high tide line and Section 10 Rivers and Harbors Act up to mean high water). Approximately 5.00 acres of other waters were observed in the Project Area. On March 3, 2012, the Corps made a final jurisdictional determination of section 404 and section 10 waters (Figure 3). The Petaluma River has been documented to support special -status wildlife species (CDFG 2011). It is considered Critical Habitat for Steelhead - Central California Coast ESU (Oncorhynchus mykiss irideus), a federal threatened species. The Petaluma River also has the potential to support Chinook Salmon (Oncorhynchus tshawytscha) in the Project Area. These wildlife species are discussed in more detail in Section 4.2.2. Coastal Brackish Marsh Coastal brackish marsh is found at the interior edges of coastal bays and estuaries and is often adjacent to Salt Marsh, another sensitive habitat type. This community has some plants in common with salt marsh, but soil and water in this habitat generally has lower salt concentration than salt marsh because of freshwater input, although salinity will typically vary considerably with tide or season. In the Project Area, marsh vegetation is sparse and consists mainly of saltmarsh bulrush (Bolboschoenus maritimus) and California tule (Schoenoplectus californicus). Other plant species include marsh gumplant (Grindelia stricta), pickleweed (Sarcocornia virginica), and salt grass (Distchlis spicata). 4.2 Special -Status Species 4.2.1 Plants Based upon a review of the resources and databases given in Section 2.3.1, 30 special -status plant species have been documented in the vicinity of the Project Area (CNDDB 2011, CNPS 2011), however, none of these 30 species are likely to be present in the Project Area. The vegetated areas consist of three communities, two of which (ornamental and ruderal) that typically do not support special -status plant species because they are areas previously disturbed and are either extensively managed and maintained (landscape) or are dominated by non-native weeds that out compete native plants (ruderal). The third community, coastal brackish marsh, is a fringe along steep river banks dominated by tall tules, and this habitat is not suitable for the special -status tidal plants listed as having potential for presence. In addition, the Project Area communities are in a relatively isolated, urban location that is not conducive to allow introduction, colonization, or establishment of special -status plants. For all of these reasons, presence of special -status plants within the Project Area is highly unlikely. No special - status plants were observed during the plant survey or other site visits. Appendix B summarizes the potential for occurrence.for each special status plant species occurring in the vicinity of the Project Area. 4.2.2 Wildlife Fifty-eight special status -species of wildlife have been recorded in the vicinity of the Project Area (CDFG 2011, USFWS 2011). Appendix B summarizes the potential for each of these species to occur in the Project Area. No special -status wildlife species were observed in the Project Area during site visits, and most are considered unlikely to be present. However, two fiP special -status fish species are known to be present in the Project Area, Steelhead and Chinook Salmon. Additional species, although still considered as unlikely to be present in the Project Area, have been added to the discussion for completeness in response to comments received concerning the proposed IS/MND and new information. These species include two fish, longfin smelt (Spirinchus thaleichthys) and preen sturgeon (Acipenser medirostris) and several species of bats, collectively. Steelhead - Central California Coast ESU (Oncorhynchus mykiss irideus), Federal Threatened Species. The Central California Coast ESU includes all naturally spawned populations of steelhead (and their progeny) in California streams from the Russian River to Aptos Creek, and the drainages of San Francisco and San Pablo Bays eastward to the Napa River (inclusive), excluding the Sacramento -San Joaquin River Basin. Steelhead typically 4 migrate to marine waters after spending two years in freshwater, though they may stay up to seven years. They then reside in marine waters for 2 or 3 years prior to returning to their natal stream to spawn as 4 -or 5 -year-olds. Steelhead adults spawn between December and June. In California, females typically spawn twice before they die. Preferred spawning habitat for steelhead is in perennial streams with cool to cold water temperatures, high dissolved oxygen levels and fast -flowing water. Abundant riffle areas (shallow areas with gravel or cobble substrate) for spawning and deeper pools with sufficient riparian cover for rearing are necessary i for successful breeding. f Central California Coast Steelhead migrate up the Petaluma River in the fall and winter to spawn in the winter and spring. Though the Project Area does not provide suitable gravel substrate for spawning, adults of this ESU likely migrate through in search of spawning habitat, and juveniles may find suitable protective cover and foraging habitat in the Project Area. The Petaluma River is considered Critical Habitat for this ESU by NMFS (2007), and CNDDB records indicate that this ESU has been observed in the Petaluma River system within five miles of the Project Area (CDFG 2011). Therefore, the Project Area represents migration and potentially rearing habitat for this species. Chinook Salmon - Central Valley Fall/late fall -run ESU (Oncorhynchus tshawytscha), NMFS Species of Concern, CDFG Species of Special Concern. The Central Valley Fall/late i' fall -run Evolutionarily Significant Unit (ESU) includes all naturally spawned fall -run populations from the Sacramento - San Joaquin River mainstem and its tributaries. Late -fall run chinook salmon are morphologically similar to spring -run chinook. They are large salmonids, reaching 75-100 cm SL and weighing up to 9-10 kg or more. The great majority of late -fall chinook salmon appear to spawn in the mainstem of the Sacramento River, which they enter from October through February. Spawning occurs in January, February and March, although it may extend into April in some years. Fry have emerged by early June, and the juveniles hold in the river for nearly a year before moving out to sea the following December through March. The specific habitat requirements of late -fall chinook have not been determined, but they are presumably similar to other chinook salmon runs and fall within the range of physical and chemical characteristics of the Sacramento River above Red Bluff. Following winter rains, this species may migrate through the Project Area in search of appropriate spawning habitat. In the Project Area, no gravelly substrate characteristic of Chinook spawning habitat is available; however, the aquatic habitat onsite may provide suitable rearing and foraging habitat for juveniles. Although the Petaluma River is outside the currently established range of this species, this ESU has been observed here (pers. comm., Amanda Morrison, NMFS). 11 Longfin Smelt (Spirinchus thaleichthys), Federal Bay -Delta DPS Candidate, State Threatened. U.S. Fish and Wildlife Service has listed the Bay -Delta distinct population segment of longfin smelt as a candidate endangered or threatened species (other longfin smelt populations have not been listed) in a 12 -month finding announced in March 2012. Longfin smelt are considered pelagic and andromous, spawning in freshwater and moving into estuarine and ocean waters as they mature with salinity ranging between 14 to 28 parts per thousand (ppt). They do not tolerate water temperatures higher than 22 degrees Celsius and typically move seaward to San Francisco Bay and cooler water during the summer. Spawning typically occurs between January and April, but may begin as early as November and last as late as June, and occurs over sandy substrate. This fish is documented to occur throughout San Francisco Bay and the delta region. Recent surveys cited by CDFG (CDFG 2012) indicate occurrence in the Petaluma River, however the documentation was not able to be obtained in time for inclusion in this report. While longfin smelt may be in the Petaluma River and within the Project Area during portions of the year, it is unlikely they are in the upper Petaluma River and the Project Area during the summer when water temperatures reach intolerable levels. Water temperatures at the Project Area (Petaluma River Turning Basin) were measured to already be 22.9 degrees Celsius (73.2 degrees F) in late May of 2004 (Cohen et. al. 2005). CDFG has determined an acceptable work window for the Project Area to be between Julv 1 and September 30. Green Sturgeon (Acipenser medirostris), Federal Threatened Southern DPS, CDFG Species of Special Concern. Green sturgeon is a large (to 7 feet) anadromous fish present in coastal waters along the west coast. Adults spawn every two to five years returning to upper reaches of freshwater streams with deep turbulent waters in late February with peak activity from April to June. Critical Habitat designation has been proposed but not finalized, and the designation includes tidal areas of the Petaluma River and the area of the project. However, available data indicate that green sturgeon have not actually been observed upstream of the mouth of the Petaluma River at San Pablo Bay but juveniles may forage in the river. NMFS concluded in a Biological Opinion (NOAA 2009) for Caltrans bridge construction work at several locations along the Petaluma River that green sturgeon were unlikely to be present in the reach between the Highway 101 bridge crossing and Washington Street bridge, which is the reach of the Project Area. Bats, including Pallid Bat (Antrozous pallidus), Townsend's Big -eared Bat (Corynorhinus townsendii), Western Red Bat (Lasiurus b/ossevillii), Hoary Bat (Lasiurus cinereus), and Silver -haired Bat (Lasionycteris noctivagans). Various status designations from Species of Special Concern to Western Bat Working Group Priority lists. All of these bats were considered unlikely to be at the Project Area based on records occurrences that indicate the nearest bat occurrence was more than a mile away (Pallid bat) and proximity of the Project Area to human activity in the downtown area. California State Lands Commission indicated that non-use of the fenced -off trestle could potentially attract bats, and out of an abundance of caution this is discussed here. All bats typically hibernate between the months of November and March and are active between April and October for breeding and foraging. These activities describe the types of fixed habitat needed by bats, including for hibernation, maternity, and day/night roosting. Hibernating habitat requires conditions where there is no disturbance and low temperatures are maintained between 1 degree Celsius (33.8 degrees F) and 12 degrees Celsius (53.5 degrees F) so 12 that bats can enter a period of reduced metabolic activity (torpor) to conserve energy. Temperatures below freezing can be lethal and warmer temperatures may cause bats to become active at the wrong time of year and risk starvation. Maternity sites are sensitive to disturbance and also need to have conditions where relatively high temperatures are reached and a space that is large enough for several females and young. They typically include a cavity or "heat trap" where temperatures are maintained between 30 degrees Celsius (86 degrees F) and 40 degrees Celsius (104 degrees F). Day roosts are occupied during the day when not foraging and night roosts are places for bats to rest between periods of foraging. Because of the openness of the trestle structure, it is not likely that conditions are appropriate for either hibernation or maternity habitat. Air circulation through the structure in winter could reduce temperatures to below freezing at times or above 12 degrees Celsius during warm days in winter. Similarly for maternity habitat, air circulation through the structure probably does not allow conditions where high temperatures are maintained even if spaces for rearing are present. Bats could find use of the trestle for day and/or night roosting, but because they are capable of escape the would fly away upon any disturbance. 5.0 SUMMARY AND EVALUATION OF POTENTIAL IMPACTS One sensitive plant community, coastal brackish marsh, was identified within the Project Area. All special -status plant species and most wildlife species listed as having potential to occur were rated to have low potential to no potential to be present based on habitat types and conditions (Appendix B). Two special status wildlife species, Steelhead and Chinook Salmon, have been recorded as present within the Project Area. The following sections evaluate potential impacts that may be caused by trestle construction as well as make recommendations for measures to avoid or reduce potential impacts to these species and sensitive habitats. 5.1 Biological Communities Coastal brackish marsh is a sensitive biological community regulated by the CDFG under Section 1602 of the State Fish and Game Code, and is a wetland regulated by the Corps under Section 404 of the Clean Water Act and the RWQCB under the Porter Cologne Act and Section 401 of the Clean Water Act. Approximately 0.36 acre of coastal brackish marsh is present within the Project Area. Additionally, approximately 5.00 acres of "other waters" (the Petaluma River) are present and within the jurisdiction of the Corps, RWQCB, and CDFG. A preliminary jurisdictional wetland delineation was completed, and the Corps of Engineers made a final jurisdictional determination on March 9, 2012. The amount of jurisdictional area extends to the high tide line, including waters and coastal brackish marsh, is approximately 5.36 acres. 5.1.9 Potential Impacts 1. Coastal Brackish Marsh. The proposed project will potentially impact coastal brackish marsh and waters during construction, which may include the following: -1-7 a. Placement of fill that will remove habitat permanently resulting from installation of the retaining wall, trestle pile wraps and replacements, and installed piles and shading if the 13 pedestrian walkway is implemented. 27 b. Temporary impacts caused by anchoring of the floating dock when it is temporarily re -located, temporary disturbance in the area slope stabilization improvements, temporary disturbance in areas during pedestrian walkway construction, and temporary disturbance of sediment during pile wrapping and replacement. These impacts will require permit authorization from the regulatory agencies, and will likely include: • Section 404 Nationwide Permit from the Corps of Engineers for Impacts to wetlands and "other waters" • Section 401 Water Quality Certification from the San Francisco Regional Water Quality Control Board related to the 404 permit • Section 1602 Streambed Alteration Agreement from the CDFG A mitigation and monitoring plan will also be needed for authorization of permits to ensure permanent impacts are mitigated through compensatory replacement of habitat and temporary impacts are mitigated by returning habitat conditions to pre -construction conditions. The Section 401 and Section 1602 permits will also require a certified CEQA document prior to being authorized. 2. Ordinance Trees. One tree may need to be removed during construction of the slope stabilization improvements or pedestrian walkway. None of the trees in the Project Area, including California natives, are considered heritage or landmark trees protected by City Ordinance. Because of the time needed for a tree to grow and the longevity it typically provides to a mature landscape, tree removal should be avoided, if practicable. However, tree removal in the area of trestle construction work would not be considered a significant impact and no mitigation would be required. 5.1.2 Mitigation Measures The impacts to coastal brackish marsh identified above may be mitigated to a less than significant level by the following: 1. Avoid and/or minimize permanent impacts to coastal brackish marsh (Figure 3) caused by filling by reducing the amount of area filled or conduct the work above the high tide line, as much as practicable. 2. Impacts to coastal brackish marsh that are unavoidable shall be mitigated by replacement of similar habitat with similar functions and values at a suitable nearby location at no less than a 1:1 ratio. A mitigation plan will be prepared by a qualified biologist that describes how permanent loss of brackish marsh caused by the project will be replaced The plan shall include performance criteria for establishment of brackish marsh plants that, at a minimum, requires plant coverage of a minimum 80 percent of cover and species similar to a nearby brackish marsh reference site five years after implementation of the mitigation plan. 14 3. Temporary impacts are to be limited to the smallest area possible required to install anchoring for the floating dock, the slope stabilization improvements, the pedestrian walkway, and various pile work. Where it is practical to do so, protective materials will be laid down to protect soil and vegetation, such as geotextile fabric onto which excavated soil or other materials are to be placed, plywood to create walkways for construction workers, silt fences to prevent soil or debris from falling into the river, or whatever situations may require. All temporary impacts will be repaired after work is completed, such as removing excess excavated soil, removing protective materials, leveling soil to original contours, replanting as needed, and use of erosion control best management practices to prevent sediment in runoff. Specific repair descriptions will be prepared by a qualified biologist to be included in the mitigation plan. 5.2 Special -Status Plant Species Because of the isolation of the Project Area and the small size of the naturally vegetated area, no rare plants are likely to occur in this area and thus, rare plant surveys are not required. 5.3 Special -Status Wildlife Species Most of the species found in the review of background literature occur in habitats that are not present in the Project Area. In addition, the Project Area occurs on and around a railroad trestle along the Petaluma River in an urban setting in downtown Petaluma which creates continuous disturbance not tolerated by most special -status wildlife species. For these reasons, most r special -status wildlife species are not expected to be present (Appendix B). Of the 58 special status wildlife species known to occur in the vicinity of the Project Area, tvva three fish were determined to have the potential to occur in the Project Area and, in fact, two have been observed in the past. These two fish species are Central California Coast Steelhead and Central Valley Fall/late fall -run Chinook salmon ESU. CDFG is reporting that longfin smelt has been observed in the Petaluma River during recent studies (CDFG 2012). Green sturgeon has not been observed in the Petaluma River in upstream reaches, and NMFS has determined that it is unlikely to be present in the area of the project (NOAA 2009). 5.3.9 Potential Impacts The waters and mudflat habitat in the river do not provide suitable spawning habitat for these special -status fish species. However, this aquatic habitat may provide suitable foraging or rearing habitat for juvenile special -status fish and/or for adult fish that may be passing through the work area between November and June each year. Potential impacts that may be caused by the project could include the following: 1. Disturbance of mudflat substrate during construction activities, such as work on piles, retaining wall construction, anchoring and removal of anchors of work barges, and anchoring of floating docks, could result in sediment entering the water column. 2. Loss of habitat resulting from approximately 192 square feet (0.004 acre) of river bottom occupied by repair and replacement of piles, which is considered insignificant, and loss of approximately 0.03 acre of coastal brackish marsh vegetation by shading and piles resulting from construction of the additional pedestrian walkway. 3. Noise generated during pile driving or other methods of installing new piles or repair of piles may produce sound/shock levels that are harmful to fish. 15 4. Toxic substances, including wood preservatives creosote and ACZA, that may reach the water during construction, such as from wood filings or sawdust, or leach into the water, such as from wooden piles. 5. Fuel and lubricants may reach the water during fueling, accidental discharges, or maintenance. 5.3.2 Mitigation Measures 1. In order to reduce sediment from entering the water column as much as possible, work should be conducted during the dry season summer and fall months when flow in the Petaluma River is lowest. Work on piles should be conducted at low tide as much as possible. When such work must be conducted in water, silt curtains should be used when work will disturb substrate and result in resuspension of sediments. 2. River bottom area lost to pile repair and replacement involves only approximately 192 square feet (0.004 acre), and no mitigation is needed. Loss of brackish marsh will be mitigated as described above in 5.1.2. 3. Impact hammer pile driving will be allowed if calculated noise levels are below the thresholds considered harmless to fish. If calculated noise levels are above levels considered harmful to fish, alternative methods of installing piles or repair sleeves will be used, such as vibratory hammer and/or use of noise attenuating technology to reduce noise. Pile driving. will be conducted within the shortest time as is practicable and, if possible, within the work window between August -1 July 1 and ectober 15 September 30. Pile driving methodology and scheduling will be reviewed by National Marine Fisheries Service (e.g., during ESA Section 7 consultation with other federal agency involvement) and CDFG. If the August toectober July through September work window is not sufficient to start and complete pile driving, a longer work window may be allowed at the discretion of National Marine Fisheries Service and CDFG. Project work other than pile driving may continue before, during, or after the final approved work window that allows pile driving. 4. Toxic substances, particularly wood preservatives, should be prevented from falling into the water. Drilling or sawing of wood treated with preservatives should be conducted on land as much as possible. Wood filings from drilling into preserved wood or sawdust generated while working over water will be collected in tarps or by use of other methods of capturing these materials. Pieces of wood that may accidentally fall into the water will be removed as quickly as possible. Repaired, preserved, or new piles will be wrapped with suitable material to reduce leaching of wood preservatives into the water as much as possible. 5. Existing California law prohibits the deposition of petroleum products in or placement of petroleum products where they can pass into waters of the state. Standard measures for spill prevention, such as properly maintaining equipment, having a spill prevention kit in construction equipment that use fuel or other lubricants, re -fueling of land equipment away from areas where a spill would potentially flow into water, and re -fueling of equipment on water (e.g., boats or powered barges) shall follow requirements of the Office of Oil Spill Prevention and Response. 6. A qualified biologist will be onsite to monitor initial project work and to provide a training session to work crew about the importance of following mitigation measures in order to avoid ig impacts to sensitive species. The biologist will make periodic site visits to inspect work practices and be available to provide assistance to contractors/work crews should a situation arise that could result in harm to sensitive species. The biologist will prepare a report at the conclusion of construction that describes how the project work met approved plans and permit conditions and/or document changes. Project activities have the potential to temporarily and/or permanently affect salmonid and other fish habitat; therefore, NMFS and CDFG should be consulted prior to initiation of project activities to obtain approval of impact avoidance and minimization measures. The Petaluma River has been designated as Critical Habitat for Central California Coast Steelhead by NMFS (2007) and for Green sturgeon (NOAA 2009). Central California Coast Steelhead and Green Sturgeon are protected under FESA, and activities with the potential to affect Steelhead and Green sturgeon populations require consultation, formal or informal, with NMFS. 5.4 Migratory Birds In addition, most bird species, even common ones, are protected under the Migratory Bird Treaty Act when nesting. Impact avoidance and minimization recommendations are discussed below. Upland habitat is ruderal, fragmented, and partly ornamental, with some trees, shrubs, and grasses providing low -quality nesting habitat for wildlife. Removal of trees or shrubs and ground vegetation where nesting could occur should be removed during the non -breeding season (September through January), and no surveys would be required for during this period. If tree removal and construction can not be avoided during the breeding season (February through August), pre -construction surveys will be conducted within 14 days prior to start of work to identify active nests. Active nests must be protected by establishing exclusion buffer zones around them until the young have fledged. Work can continue in areas outside of the buffer zones and can resume within the buffer zone once the young have left the nest. 17 6.0 REFERENCES Benson, A. J., M. M. Richerson, E. Maynard, J. Larson, and A. Fusaro. 2012. Dreissena bugensis. USGS Nonindigenous Aquatic Species Database, Gainesville, FL. http://nas.er.usgs.gov/queries/factsheet.aspx?speciesid=95 Revision Date: 6/28/2012 California Department of Fish and Game. 2009. A status review of the longfin (Spirinchus thaleichtys) in California. California Department of Fish and Game. 2011. California Cooperative Anadromous Fish and Habitat Data Program (CalFish). CDFG Environmental Resources Information Services. http://www.calfish.org/Home/tabid/70/Default.aspx California Department of Fish and Game. 2011. Natural Diversity Database, Wildlife and Habitat Data Analysis Branch. Sacramento. 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Department of Environmental Science and Policy, University of California, Davis, California. http://ice.ucdavis.edu/aquadiv/fishcovs/fishmaps.htmI Jennings, Mark R. 2004. An Annotated Check List of Amphibians and Reptile Species of California and Adjacent Waters. Third, revised edition. California Department of Fish and Game. National Oceanic and Atmospheric Administration (NOAA). 2009. National Marine Fisheries Service Biological Opinion for Marin Sonoma Highway 101 Narrows Project. File No. 2007108320:DHW. National Marine Fisheries Service, Long Beach, CA. National Oceanic and Atmospheric Administration (NOAA). National Marine Fisheries Service distribution maps for California Salmonid species. August 2011. http://www.nwr.noaa.gov/ESA-Salmon-Listings/Salmon-Populations/Maps/index.cfm Natural Resources Conservation Service (NRCS). 2002. Field Indicators of Hydric Soils in the United States, version 5.0. G.W. Hurt, P.M. Whited, eds. USDA, NRCS in cooperation with the National Technical Committee for Hydric Soils, Fort Worth, TX. Reed, Jr., Porter B. 1988. National List of Plant Species That Occur in Wetlands: National Summary. U.S. Fish & Wildlife Service. Biol. Rep. 88 (24). 244 pp. Serpa, L. 1996. California Freshwater Shrimp: A Ghost-like Crustacean We Can't Afford to Lose. Tideline Vol. 16 No. 2 1-3. Published by: Don Edwards San Francisco Bay National Wildlife Refuge. Newark, CA. Shuford, W. D. 1993. The Marin County Breeding Bird Atlas: A Distributional and Natural History of Coastal California Birds. California Avifauna Series 1. Bushtit Books, Bolinas, CA. Stebbins, R.C. A Field Guide to Western Reptiles and Amphibians, 3rd Edition. 2003. The Peterson Field Guide Series, Houghton Mifflin Company, New York. U.S. Department of Agriculture, Soil Conservation Service.1972. Soil Survey of Sonoma County. California. In cooperation with the University of California Agricultural Experiment Station. United States Fish and Wildlife Service (USFWS). 2008. Endangered Species Program, Arcata Fish and Wildlife Office. United States Fish and Wildlife Service (USFWS). 2012. Endangered and Threatened Wildlife and Plants; 12 -month Finding on a Petition to List the San Francisco Bay -Delta Population of the Longfin Smelt as Endangered or Threatened. San Francisco Bay -Delta Fish and Wildlife Office, Sacramento, CA. 19 USFWS. 2008. Quadrangle Species Lists, Sacramento Fish and Wildlife Service. Zeiner, D. C., W. F. Laudenslayer, Jr., K. E. Mayer, and M. White. 1990. California's Wildlife, Volume 1 -III: Amphibians and Reptiles, Birds, Mammals. California Statewide Wildlife Habitat Relationships System, California Department of Fish and Game, Sacramento. E U _ M� . 0 if ^ o 'w 7�5 O` C i } ' C f6 c2 may., q � O ''(^D vJ �0 3 cd O C Uo m O C Q._ 2 V N w e cn c m w 3'-• Em3v777 C W N C N� z aO'OU C (Q L in rn c W �'� a) - N o »L 'z aa)i w CL 4�" ILig -7Q o U 1 c J ^ 00 000 4 42 Z 3 75 c +� cn U =2)42) �1 Y N rn M� . Aw5 l 0 if ^ o ` o✓ � i } ' �to q � O ''(^D vJ 'C m C -.8 .5 N °' �' cn c C W N C v - O p 0.1 rn c W W Q' - o U w CL 4�" H -7Q o U = � c J ^ 00 000 4 42 Z 3 75 c +� cn U =2)42) �1 Y N rn LO Aw5 l if o ` o✓ � i } ' �to q a 'C C -.8 .5 N °' �' •N, ani p 0.1 v 4�" H -7Q z 42 MID � 5 c Y N o w 3 U e �T+ Aw5 l if L t ` o✓ � i } ' •�"'�' Aw5 l k' L t ` o✓ � i } ' •�"'�' APPENDIX A PLANT SPECIES OBSERVED IN THE PROJECT AREA fm7 i i� CO _ U J J J U Q J— Z U Q U J U Q J m U J m J J J J J J w U J U Q U a' a) ' Q Z Z Z Q LL Z LL Z LL O < O Z Z Z Z Z Z LL f LL LL LL LQL N -Cc Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z L Z m <_ a) z3 a a a) a) N L .0 yr �_ Q Q Q Q Q Q y Q Q Q Q ' a) �.. \ a) 'O a) 'a \ .0 L a Z Z :E E Z Z Z Z Z Z Z Z Z Z C = _ cu M — m a) a) a) a) a) a) a) a) m a) a) a) m a) (L) a) (1) M m m t6 > m m m m m m m > > > co > m m m> > m m > C C C C C C C C C C C +� C C C C C '+• C C +_+ C _ C C C C C C C C C C C C C C lu M a C C C C C c O O O O O 0 0 0 0 0 0 O O O O O O a O c O cC O .E .0 � :a O c O c E =5c o — E . E C 'Q � tll .� .� � '4 m m m L .0 L .0 •Q m m 4O> ..Q .Q ..O .O 4O 0 4 L L m L .fl .fl co O v- L O) L O) �.,. m m C a) m m o 0 o co m m m m 4- a) �° 00 m O a) m m V- •C C m m •C •C m CCS m C •C m •C , C ' c m a) a) (6 •C NCC d C - i) N C `4= a) a) a) > CC C a) () C C C C C a) a) C a) a) a) C C a) > C C c C (y > C C m C a) a) J a s a) m a a m m m a a m a a s m () m m 0 m a m a a a a) � 0) a) ZZ a) c to a) n n C '`• a M a i c75 L a) >to c a) a c —0 U (n oE a) a) o a) co c E to C -aN .�U Em m _ to )to m a)O� +> -VOE CCi 'U CEL 'c () _ _ a C COa� a`) .c w U a E .0 a O a s a to o N O U a m w.. U > 'O 77 co to U co a a c c E m o O �( "6 �° 0 to N ti c c y m d a) c U> a) yZ3m n L O V N m O h E 'O Eo U CO L m v t7 C'�:Nv C w:03 v oa i m v) mo N m U O Q U m Cc))m c x co m o w m ") o h E m y o y m m EE E m Q Z3 m o L m c c a) .c c m m m �U O Q) -� N fU0 O C�6 4 O 0U 0 m Ll. _ Q- C) (D m= --j Co J m U 0 U Ch W J W W Q T m m U N N a) a) a) a) N 0) cu m m m U 41 m N m m N m U U U` Ua) a) U U U U U .0 6 m UU m m m m L (6 L m O L O > N V `UUU to o o o N N T T m a) N c C OUN O O IL < Q Q Q Q Q Q Q Q Q m m U U U C.) w CD 0 2 0 0 0 a w a / / C) / / / 4- 0 ( f / � 7 3 3 7 ® / z z z z 7 = n a G / W k m 7 � = ? = m q 0 z a E 7 cu - (1) \ \ $ \ U \ \ e 2 O c e c / \ \ 0 c 0 0 2 E E \ / \ / 2 / 0 .r- % / \\ :3 \\ /O \ % % a \ \ .E 2 » m m \ = c 2 2 a m m m e e\ c CL k \ ¢ G Sco § 2 ± � = a \ 2 2 Cf) - \ \ 2 0 \ / o = u e = t 7 cu r w / 0 2 \ / 2 ) 7 / g E � \ \ to \ % / » ® \ m 6 2 o§ © § a 2 n ® m m / \ ® % / Z \ k % I c » ® a m 0 E C% c c co ± % % • % E nk a� \�\°�k�\\ C,) k m t \ §gym* a) co m m e Q e\/ 0 0 \ \ 7 E ( 0 0 j ( k \ \ % � q a \ \ 0 0 0 0 :3 E I & m O .. . POTENTIAL FOR SPECIAL STATUS PLANT AND WILDLIFE SPECIES TO OCCUR IN THE PROJECT AREA L 'O a (D 0 N U 0 Z (a 4- ca (n O 0 O i) o C7 O C Cn L (a U C (a �+ E O 0 00 U)oa M W c U) ca L 0_ N Z O M U (a C O (a O U) 0 L C N > O U Y 0 (6 C 0 � m � O O a) L 0_ Z v U 0 _:,,2 A � U E o N (6 U) aa) u) o U C o a) y N N E a a) 5 a) (a a a a) c U) 0 C � C6 O Q U) 0- "U) E (Q N 0 � � a � v E Q) 'Q O E o O U) m U x T) aa) J W Q N Q Q C� N t6 (a N (a (a 0 W N Q) a) a) U a) a) N .Q .Q .n .n .o Z ca ca 05 ca ca c�a ca ca (n (n (n U) (n (1) (n (1) ) U) Y Y Y Y Y Y U (a c-oa ro c-oa m U- O ca ca U (a o ca ro (a ca 0 N Q a) N Q (n O Q N Q N Q () Q O Q a) Q � U U U U U U U U a) a) O O a) N O a) 'J Q O O L O •O L_ O O I - a aL /O n o a /O C C- 0_ Z (D a) CU U a) a) Q) U a) H co �- F vi f- H c/)F ui .0 F ui L F- co O o 0 o m a) a) 0 C O C L C O C O C O C O C O C O N Q N N a) a) CO +"� N CLN CO (n Q O N N Q. U O N Q N O a) Q el) (n a) Q y O 0_ 0_ 0_ 0_ 0_ 0_ 0_ ..0 0_ Z 0 0 Z4 Y +J Z- rt +, Z.2 Z 2 Z 2 *- Z4- Z C N E (n C .0 O E _ L _0) O .� U O C O a) a) a C c O E O a E O (a (a N E C O O O c- (a > C N (a '- F- """' Q C N Sc U O O p a) 7 `- a E Q. (n (a W O ? Q N O) 0- > '� LO C OD C p a) (n ,C @ (n E C C) O1 C Ln 00 _C (6 (a O a N a) (a O N >, 0 CO O ,� r' y= O ca >, °� -o -C .� T 6� 3 0 m a O r o (a c a c a o c >+ m o O (n ca _. O > tq > r (n to L, 0 (6 > 0 O 0 C O U -a U EO '- a) E a) "� ca •- Q E U) Q E n O a) c 3 O a) m O `~ IV W C O O > N y- a (a U ca N •r0-� C tt) O to (a (a a a a 0 E. W' (a m p a (6 U - 7 v- �- O 0 0 E N C C (a C U N O (a co �' C .� C- f6 S] - - m U O (a (a E in � N N p E= p Q O U E a) a) O 0 .- 0 Q. 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Z Z Z �2 Z 2 U E a) C a) 1 C= M o E N E cn C ca a T O U a O , M ` ,gip — — C m aj L N _ — a m (n L O O m N i m m m m L m N F Z p m N N U m U N V p m a) cLa p) N LL. O .! �'�' Q. _ N N O Q Q. Q E U a) O E Y y0- > _ N a Q N L) a) c a) LO m m w m y c N 0 � �E� W C LL >i O co U-6 a) O m E 0 O p E _ a) .. CL co co a N a O +.' C ..0 T > cn .0 — U mT m o o 0 U — O p -a m 'C Q) E C C �- r N m O U a) N L a m a) •L N •m o m O m p a m c m CD > 0 0. O a N o m �- m T O N E> Q 2i a m "+ E N N Lr m aNi fl aNi E a m a) O' o c c ca m a O E m ` U (n p N m— m E u m a) Ep O m "'' N m T O O Q CO E O m Q m Z `� a .0 L O N O N m E > N p> .m I a Lf) a) L O m C E a) E 1 N �; N O �' O m a U 0 p m m m� Q po 00 � c � >, - •m O o am a .,_. N U 00 cm N m p N Lo N > S ._ m r0 CU O N "7 m 7 CO L CL O N N p E ca m a E C N ca N m c N �, m a a) _.. a) m C E >.- N m N N Q I a) (a iL. O .0 010 O �, c�a E LO i C O m O. 0 E N E N m a �' E O m O Q — a) W O LSA O m p E N a) N a) M m N m 0 0 m 0 m N M m O E N m I U O.. 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E y \ ] \ 2 0 o E o 5 ® S w 2 ® %z\\//\\©6 0)4/ \ \ 2 $ / ¥ Cl) 7 'o / y \ / / ® A / a \ \ / / ° % 2 \ % G \ \ & \ \ / / R co \ \ § U) @ CO Lu- §%% } / .m-mm2% —co 7 / \\\ G Z\ t y c x 2 2» 2 ®®a Q / 7 m ek< aim 2 %E/%/a m a » \ E E 2 \ \ 000 \\ / \ //\ /\/. \/�mm#m9 Q LU Q F- 0 LU I O w a. w x H U LL O X_ U) ❑ a Z � W 0 a a ° Q O x CL w Q E- z w U) LU w a w w Top: Historic Petaluma trestle is in state of deterioration and needs rehabilitation. Bottom: Biological communities are waters and coastal brackish marsh with ruderal habitat and ornamental landscaping on steep river banks. ENVIRONMENTAL CONSULTANTS Top: The Petaluma River is habitat for Steelhead trout and Chinook salmon which are generally present in the river from November through June. Bottom: A proposed new pedestrian walkway will cover existing ornamental landscaping and 0.03 acre of coastal brackish marsh. 3wru ENVIRONMENTAL CONSULTANTS Appendix D Comment Letters IGCt OF OF�(IF PFAM\t�GG','D' ��T STATE OF CALIFORNIA GOVERNOR'S OFFICE of PLANNING AND RESEARCH sjgrf'' "_ FG UNIT of cauco4 �z,FOR STATE CLE_�RING%ibUSE AND PLANNING � Enurtn. �sxov�Itt Jti. 1., v; CC" i = Sf f GOVERNOR � R F July 13, 2012 PUBLIC, WORKS.' Diane Ramirez City of Petaluma 11 English Street Petaluma, CA 94952 Subject: Trestle Rehabilitation Project SCHM 2012062036 Tear Diane Ramirez: The State Clearinghouse submitted the above named Mitigated Negative Declaration to selected state agencies for review. On the enclosed Document Details Report please note that the Clearinghouse has listed the state agencies that reviewed your document. The review period closed on July 11, 2012, and the l comments from the responding agency (ies) is (are) enclosed. If this comment package is rot in order, please notify the State Clearinghouse immediately. Please refer to the project's ten -digit State Clearinghouse number in future correspondence so that we may respond promptly. Please note that Section 21104(c) of the California Public Resources Code states that: "A responsible or other public agency shall only make substantive comments regarding those activities involved in a project which are within an area of expertise of the agency or which are required to be carried out or approved by the agency. Those comments shall be supported by specific documentation." These comments are forwarded for use in preparing your final environmental document. Should you need more information or clarification of the enclosed comments. we recommend that you contact the commenting agency directly. , This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft environmental doeutments; pursuant to the California Environmental Quality Act. Please contact the State Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review process. Sincerely, Scott Morgan Director; State Clearinghouse Enclosures cc: Resources Agency 140010th Street P.O. Box 3044 Sacramento, California 95812-304 1916) 445-0613 PAX (916) 323-3018 www.opr.ca,gov Document Details Report State Clearinghouse Data Base SCH# 2012062036 Project Title Trestle Rehabilitation Project Lead Agency Petaluma, City of Type MND Mitigated Negative Declaration Description The City proposes to rehabilitate the existing Trestle, implement slope stabilization repairs, install educational features along the waterfront, and potentially construct a new pedestrian walkway along the Petaluma River. These project components are collectively referred to as the Trestle Rehabilitation Project. Lead Agency Contact !Name Diane Ramirez Agency City of Petaluma Phone 707 776 3658 Fax email Address 11 English Street City Petaluma State CA .Zip 94952 Project Location County Sonoma City Petaluma Region Lat/Long 38° 14'3,33" N / 122° 38'19.89" W Cross Streets Western and B Streets Parcel No. Township 5N Range 7W Proximity to: Highways Hwy 101 Airports No Railways SMART Waterways Petaluma River Schools San Antonio, McKinley Land Use FW - Floodway Section 33 Base MDB&M Project Issues Aesthetic/Visual; Air Quality; Archaeologic -Historic; Biological Resources; Flood Plain/Flooding; Geologic/Seismic; Noise; Recreation/Parks; Solid Waste; Toxic/Hazardous; Vegetation; Water Quality; Wetland/Riparian; Landuse Reviewing Resources Agency; Department of Boating and Waterways; Department of Conservation; Department Agencies of Fish and Game, Region 3; Office of Historic Preservation; Department of Parks and Recreation; Department of Water Resources; California Highway Patrol; Caltrans, District 4; Regional Water Quality Control Board, Region 2: Native American Heritage Commission; Public Utilities Commission; State Lands Commission Date Received 06/12/2012 Start of Review 06/12/2012 End of Review 07/11/2012 z' STATE OF CALIFORNIA EDMUND G. BROWN JR., Governor CALIFORNIA 'STATE LANDS COMMISSION 100 Howe Avenue, Suite 100 -South Sacramento, CA 95825-8202 ILI July -11,2012 City of Petaluma Attn: Diane Ramirez 11 English Street. City of Petaluma, CA 94952 CURTIS L. FOSSUM, Executive Officer (916) 574-1800. FAX (916) 574-1810 California Relay Service From TDD Phdhe 1.800-735-2929 from Voice Phone 1.800-735-2922 Contact Phone; ' (916) 574-1960 Contact FAX. (916) 574-1885 File Ref: SCH # 2012062036 Subject: Environmental Assess ment/lnitial.Study/Mitigated Negative beclaration (EA/IS/MND) for the Trestle Rehabilitation Project, Petaluma River, Sonoma County Dear Ms. Ramirez;. The California State Lands Commission (CSLC) staff has reviewed the subject EA/IS/ MND for Trestle Rehabilitation Project (Project), which is being prepared by City of Petaluma (City). The City, as a public agency proposing to carry out the Project, is the lead agency under the California Environrne ital'Quality Act (CMA) (Pub. Resources Code, § 21000 et seq.). The CSLC is a trustee agency because of its trust responsibility for projects that could. directly or indirectly affect sovereign lands, their accompanying Public Trust resources or uses, and the public easement in navigable waters. Additionally, since the Project involves work on sovereign lands that will require a lease from the CSLC, the CSLC will act as a responsible agency. CSLC Jurisdiction .and Public.Trust Lands The CSLC has jurisdiction and management authority over all ungranted tidelands, submerged lands, and the beds of navigable lakes and waterways. The CSLC also has certain residual `and review authority for tidelands and submerged lands legislatively granted in trust to local jurisdictions (Pub. Resources Code, §'§ 6301, 6306). All tidelands and submerged lands, granted or ungranted, as well as navigable lakes and waterways, are subject to the protections of the Common Law Public Trust. As..general background, the_S.tate_of.California acq.uired..sovereign ownership.of.all..._. tidelands -and submerged lands and beds .of navigable lakes and waterways upon its admission to the United States in 1850.' The State holds these lands for the benefit of all.people of the. State for statewide Public Trust purposes,_which include but are not limited to waterborne commerce, navigation, fisheries, water -related recreation, habitat preservation, and open space. On tidal waterways,, the State's sovereign fee ownership. extends landward to.the mean high tide line except for areas of fill or artificial accretion or where the boundary has beer! fixed by agreement or a court. On.navigable non4idal waterways, including lakes, the State holds fee ownership of the bed of the waterway landward to the ordinary low water mark and a Public Trust easement landward to the Diane Ramirez Page 2 July 11, 2012 ordinary high water mark, except where the boundary has been fixed by agreement or a court. Such boundaries may not be readily apparent from present day site inspections. A portion of the Petaluma River, over which the proposed Project will extend; includes State-owned sovereign land. Prior to the commencement of any work, a lease and formal authorization for the use of sovereign land will be required from the CSLC for the portion of -the project encroaching on State-owned lands. A lease application is available on our website at www,slc.ca.gov. Project Description The Petaluma Trestle (Trestle) is currently owned by Sonoma�Marin Area Rail Transit. It is located at the'Petaluma Waterfront, where Western and 13'8treets terminate on the south bank of the Petaluma River (River) in Petaluma. The proposed Project would rehabilitate the deteriorated Trestle to make it a safe, functional part of the River waterfront in accordance with Policy 2-P-11 of the City of Petaluma General Plan 2025 (General Plan). The construction is expected to last from 4 to 5 months and includes the following key components; • Rehabilitate the existing Trestle; • Implement slope stabilization repairs, ' • Install educational features along the, waterfront; and • Potentially construct a new pedestrian walkway along the River.. The City intends to reuse as much of the existing Trestle comparients as feasible. There are a total of 178 Trestle piles, of which approximately 173 creosote -treated timber piles would be replaced or repaired; additionally, approximately 16 new piles could be installed to support the potential pedestrian walkway. CSLC staff requests that the City'consider the following comments and incorporate appropriate revisions prior to adopting the EA/IS/MND. Environmental Review Project Description 1: The EA/ISWND would benefit from a more detailed discussion of the proposed construction procedures for the structures in Section 1.3. Currently, the description does not state preferred options for materials, nor does it include in the environmental analysis a discussion or comparison of the potential impacts of each option being considered. Additionally, a more detailed discussion of the equipment needs -and -timing of the construction- and. would also-help-iri understanding the environmental impacts from the proposed Project. For example, while the description on pages 4 and 5 of the EMWIVIND states that some piles - - - - would-be "wrapped with PVC or HDPE sheets;" others would "have -a steel,' HDPE or FRP jacket placed over the existing pile," and others would be cut at the mudline or fully removed, the description does not discuss how these measures -would be implemented, including whether temporary cofferdams or other .dewatering Diane Ramirez Page 3 July 11, 2012 methods would be necessary, or whether the wrapping.and jacketingcan be performed in -water. By omitting this important information, the EA/IS/MND may not, in turn, present a complete and accurate assessment of potential effects on aquatic biological resources, as the impacts would be different under each scenario. CSLC staff recommends clearly laying out all preferred options with the relevant information regarding its stages of construction phases, timing, and equipment needs. 2. CSLC Approval: The EA/IS/MND on page 6 lists agencies with approval authority over the project. CSLC staff requests a change in the language for CSLC approval from "a lease n2ay be -needed" to "a lease will -b-e needed" for the portion of the River over which the proposed Project would extend. Please see the jurisdictional information above for more information. Recreation 3. Water"Based Recreation. The EA/IS/MND on page'64 analyzesthe Project's potential impacts on recreational facilities, but does not evaluate uses of the Project area and its surroundings by the public (e.g.., kayakers, 'bdaters, swimmers, etc.) or how construction could. preclude, use by recreators. Although the ' Environmental 'Checklist in Appendix G 'of the State CEQA Guidelines does not specifically require analysis of a project's conflict with recreational activities not connected with a particular facility, the public's water-based recreational activities on submerged lands are. protected under the Public Trust Doctrine. As a trustee agency, the CSLC requires further information on the Project's impacts on water- based recreation and public access to the River, as well any measures the City would take to avoid or minimize impacts. Additionally, CSLC staff recommends posting signs around the Project area in an effort to make the public more aware of construction .activities, and developing alternative access to the River, if necessary. Water Quality.and Toxicology t 4. Sediment Disturbance. The Project would involve activities such as pile driving, and construction and deconstruction activities which can disturb River sediments, resulting in toxins such as mercury entering the water column and impacting downstream resources. For example, the methylation of mercury into methyimercury, an organic form of mercury that can bioaccumulate in aquatic species and poses a threat to human health, is a persistent problem in California's waterways; if the Project has the potential to contribute to downstream mercury loads, the impact may be cumulatively significant: Therefore, CSLC staff asks that the EA/IS/MND analyze the Projects _potential effects on the release of.toxins, :.. including mercury if present, in the sediment. If impacts are found to be potentially significant, the EA/IS/MND should identify avoidance and minimization measures to reduce potential release of such toxins. into waterways from Project activities.. This could include, but not be limited to, a soil testing and reporting plan, and if The State "CEQA Guidelines" are found in Title 14 of the California Code of Regulations; commencing with section 15000. Diane Ramirez Page 4 July 11, 2012 appropriate based on those tests, development and implementation of a -containment and disposal plan. Also, Mitigation Measure HVVQ-2, "Reuse of Creosote Treated Wood in Aquatic Environment," states -on page 49 of IS/EA/MND that "the contractor shall wrap or seal all creosote -treated wood components that are to be reused within the aquatic environment up to the MHHW-line. These components shall include:piles, and sash and sway bracing. However, as indicated earlier in this lette'r,.there is no mention of where this treatment will take place. Please clarify whether the wrapping/sealing would be in -water or whether dewatering would be necessary: Additionally, the EA/IS/MND would benefit from clearly stating all efforts aimed at minimizing contamination of the River from all possible construction -related . activities by building temporary structures such as cofferdams. Biological. Resources 5. Special -Status Bats. The EA/IS/MND under the "Biological Resources" section on page 23 does not include a discussion of.the proposed Project's potential to impact speciakstatus bats or indicate whether any pre�demolitibri surveys or ongoing monitoring would be implemented to ensure these species are.not affected. While Appendix C "Special -Status Species" lists bats such as pallid bat, Townsend's big eared bat, western red bat; hoary bat, and silver haired bat as ""unlikely" to be present in the Project area, there is no,reference to bat surveys having been completed, nor inclusion of a biological resources survey report.. Reliance on "desktop" methods'such as searches of the California Natural Diversity Database (CNDDB) and/or U.S. Fish and Wildlife Service species lists is not, adequate evidence by itself to conclude impacts would not occur. While the EA/IS/MND references a "2012 survey" and'"site visits" in the biological resources section, no survey methodology, survey report, observed species list, or any other evidence is presented in the document, and therefore CSL.0 staff is unable to concur that the EA/1S/MN-D provides adequate support -for its conclusions. Because these areas have been closed off to public as hazards, it is possible that bats are roosting in or are otherwise using these old and undisturbed structures and the Project vicinity generally. CSL.0 staff recommends including a discussion of the Trestle's potential habitation by bats and, if bat presence is established; identification of feasible avoidance or minimization measures in the EA/IS/MND. 6. Underwater Noise and Vibration. While on page 27 -the EA/IS/MND acknowledges the potential impacts of underwater noise from pile driving on special -status species, there appears to be no discussion of in -water noise and vibrations that could --result from the use of other construction and demolition equipment; including - bank stabilization activities, as mentioned in the Noise section on pages 55-61. CSL_C staff recommends expanding the EA/IS/MND's analysis of in -water noise - - and -vibration effects to include the potential contribution of other -construction activities, with emphasis on the following statement from page 58: "Construction - related noise levels are normally highest during the demolition phase and during the phases of construction requiring heavy equipment that normally generates the highest noise levels over extended periods of time." It would be beneficial to Diane Ramirez Page 5 July 11, 2012 include discussions of whether the demolition phase, generating the highest above -water noise levels, would add to impacts on aquatic and other species. 7. Vegetation Mitigation.Plan. Mitigation Measure BR -2, "Protect Coastal Brackish Marsh," states on page 28 that all areas temporarily disturbed during construction shall be repaired after work is completed, including "Replantvegetation with ,native species appropriate to coastal brackish habitat.... A mitigation plan "shall be prepared by a qualified biologist identifying the location, implementation (including a planting plan), and monitoring of the expanded coastal brackish marsh habitat." However, the EA/IS/MND does not include the mitigation pian (P.lan) itself, nor does the analysis,.other than a brief mention of a 1:1 replanting ratio, specify what standards or success criteria the Plan will meet, making it difficult for CSLC staff to comment on its adequacy in minimizing or avoiding impacts, Without an idea of the criteria that this Plan will -meet, the'EA/IS/MND's argument that the Project's effects on native vegetation communities will be less than significarit with mitigation incorporated is not adequately supported. Although for CEQA 'purposes the mitigation measures identified in an EAIIS%MND need not include all specific details; the EA/18/MND does need to atleast `'specify . performance standards which would. mitigate the significant effect of the project and which may be accomplished in more than one specified way" (State CEQA Guidelines, § 15126.4, subd. (b)). As currently written, the measure does not specify performance standards for the Plan itself, nor for the revegetation effort required by the Plan, this amounts to deferred mitigation. Deferral of the formulation of mitigation not only runs counter to the State CE. -QA Guidelines (§ 15126.4, subd. (b)),. but denies responsible agencies- and the interested public the chance to comment on the adequacy of the proposed mitigation for avoiding or minimizing a project's impacts. CSLC staff recorrimernds that the EA/IS/MND provide the Plan with the EA/IS/MND for review; or specify success criteria within Mitigation Measure BR -2 that revegetation efforts under'the Plan would meet (e.g., X% cover of native vegetation after X number of years). 8. Invasive Species. The EA/IS/MND should consider the Project's potential to encourage the establishment or proliferation of aquatic and terrestrial invasive flora and fauna such as the quagga mussel, or other nonindigenous, invasive species and, if-the.analysis finds,that impacts are potentially significant, identify avoidance or minimization measures as appropriate. Possible mitigation could include: • Environmental training of operational and maintenance personnel to inform them about invasive species; Actions to *be taken to prevent the release and spread of, aquatic and/or terrestrial invasive species; • Procedures for the safe removal and disposal of any invasive species observed;. • A post -operations and maintenance report identifying what, 'if any, invasive species were found attached to and/or removed from equipment and materials, as well as the treatment, handling, and disposal of identified invasive species. Diane Ramirez Page 6 July 11, 2012 CSLC staff recommends that the EA/IS/MND specify that the work. crew training session required by Mitigation Measure BR -2 also address invasive aquatic plant and animal species, because introduced invasive species at the Project site may affect surrounding Public Trust lands and could degrade Public Trust uses, resources and values. Cultural Resources 9, Shipwrecks. The EA/IS/MND describes the kinds of cultural resources that might. be encountered when digging into the River channel on page 33 as "historic debris either from fill, or from sunken ships." A search of the CSLC Shipwrecks Database* indicates five vessels that are potentially in the Project area, including the Pilot, Georgia (or Georgiana), Petaluma #2, Gold_, and Agnes Jones: Information from the database -on these vessels is enclosed: The records indicate that the ships experienced explosions or burned; therefore, remnants of the vessels, vessel parts, or cargo may still be present. The City may wish to research these incidents from newspaper accounts or contact others with special knowledge of Petaluma's maritime heritage. This could provide additional information on the likelihood of encountering these vessels or associated artifacts, before starting construction. CSLC staff requests that Mitigation Measure CR -2, ``Treatment of Previously" Undiscovered Archaeological Materials," include an additional requirement that any . shipwreck remains, associated artifacts, or cargo be evaluated by a qualified maritime archaeologist. Should any of these materials be discovered dufing Project construction on lands under the jurisdiction of the CSLC; and the find is potentially significant, the archaeologist shall consult with CSLC staff concerning treatment options. For additional information on cultural resources under the jurisdiction of the CSLC, please consult with Senior Staff Counsel Pam Griggs at the contact information noted at the end of this letter. Greenhouse Gas (GHG) Emissions 10. Quantification of Emissions. The EA/IS/MND on page 43 suggests `less than significant impact" related to the Project's GHG emissions from five months of construction, demolition, and possible disturbance of soils under water. CSLC staff supports the City's efforts to reduce emissions by applying basic construction measures such as idling times and the use of properly tuned construction equipment in order to reduce emissions; however, the analysis does not clearly _demonstrate why the remaining emissions. would.be less than_significant nor.does _ it include a quantified table of emissions as an appendix for review by the public. A GHG emissions analysis consistent with the California Global Warming Solutions Act (AB 32) and required by the State CEQA Guidelines should. be included in the EA/IS/MND. This analysis should identify a threshold for significance for GHG emissions, calculate the level of GHGs that will be emitted as a result of all Project activities, determine the significance of the impacts of those emissions, and, if Diane Ramirez Page 7 July 11, 2012 impacts are significant, identify mitigation measures that would reduce them to less than significant. Please also describe any consultation the City has had with the Bay Area Air Quality Management District (www.baagmd.goy * . For further guidance, please consult CEQA and Clim.ate.Change and Quantifying Greenhouse. Gas Mitigation Measures; they can be found on the California Air Pollution Controls Officers Association (CAPCOA) website via the following fink: www.caocoEi.org/. Cumulative impacts 11. The EA/18/MND briefly. discusses cumulative 'impacts on page 70-71. However, the analysis only identies projects identified in the General Plan EIR for the cumulative impacts analysis, and does not include other projects in the area which might have been proposed after finalization of the General Plan. CSLC staff. recommends that the cumulative impacts analysis include a description of the methodology used by the EA/IS/MND preparers to identify other projects in the area., other than those listed in the General Plan EIR, which may add to existing cumulative impacts on resources in the River, surrounding area, and downstream from sediments released into water, vibrations. and noise from Project. Thank you for the opportunity to comment on the EA/IS%MND for the'Project.- As a trustee and responsible.agency, we request that you consider CSLC staff's comment's prior to adoption of the EA/IS/MND. Please send copies of future Project:related documents, including electronic copies of f the Final EA/IS/MND, CEQA Findings, and Notice of Determination when they become available, and refer questions concerning environmental review to Afifa Awan, Environmental Scientist, at (916) 57.4-1891 or via e-mail at afifa.awarn(@.slc.ca.gov. For questions concerning archaeological or historic resources under CSLC jurisdiction, please contact Senior Staff Counsel Pam Griggs at (916) 574-1854 or via email at r pamela.grigqs(a,Slc.ca.qov.. For questions concerning CSLC leasing jurisdiction, please contact Nicholas Lavoie, with the Land Management Division, at (916) 574-0452, or via email at nicholas.lavoie@slc.ca.gov, S' erely, Cy R. Oggin hief Division of Environmental Planning and Management Enclosure cc: Office of Planning and Research - N. Lavoie, LIVID, CSLC M. Hays, LMD, CSLC A. Awan, DEPM, CSLC P. Griggs, Legal, CSLC J. Rader, Legal, CSLC Results of California State Lands Commission Shipwrecks Database Search City of Petaluma Trestle Rehabilitation Project June 26, 2012 Directions: To here - From here Directions; To here --From here Directions:To here - From here Gold QgnesJones ID—Number = 441 Georgia (Georgiana) Shfp_s_Nam=Gold Ship_s_Nam=AgnesJones iD_Number=1484 Type = Scow schooner Pilot Shfp_s_Nam = Georgia (Georgiana) Petaluma #2 Year Built=0 Type = SidewheelSteamboat Year—Sunk= 1889 1D_Number=1485 RegNo= ID_Number=598 Ship_s_Nam=Pilot Year Built=185D 'Ship s_Nam=Petalumarr2 Type- Steamship Year Sunk=1855 Type = Sidewheel Steamboat RegNo = Date_Sunk=1112311855 RegNo = Year Built=1869 Cause= Boiler explosion Year Built=1884 Year_Sunk=1883 Owner= Wagner and Behler Year Sunk=1914 Date Sunk=512511883 Captain=Thompson, J. Date _Sunk=3122/1914 Cause = Explosion Length =75 feet Cause=Burned Owner= Beam= Owner= Captain =Graves Tonnage = 30 Captain =. Length = 122 feet Engine = Length _ Beam = 25 feet County = Napa • Beam = Tonnage = 200 State Wte = yes Tonnage = 264 Engine = Latitude= 38deg 1412'N Engine = County = Napa Longitude =122deg 38'36 Al County= Napa State Wate = DecLat= 88.2367 State_�Wfate = Latitude =38deg 14'12N DecLong =-122.643 Latitude = 38deg 14'12N Longitude = 122deg 38'36W Depth = 0 Longitude=122deg 38'35W DecLat=38.2367 Quad= DecLat=38.2367 DecLong =-122.643 Descriptio = at Petaluma landing DecLong =-122.6.13 Depth =0 LocRadius = 750 Depth = 0 Quad = File_= -1 Quad = Descriptio =Petaluma Creek. Comments= Firstship to navigate up the San Joaquin Descriptio,= at Petaluma wharf LocRadius = 0 River,going as far as Firebaugh. Explosion resulted from LocRadius = 0 Ffle_ =0 captain's tieing down the saftyvafve. He was lastseen File_=0 Comments = running through the streets of Petaluma,'running like hell'. Comments= ex Resolute Directions: To here - From here Directions; To here --From here Directions:To here - From here Gold QgnesJones ID—Number = 441 ID_Numb er= 440 Shfp_s_Nam=Gold Ship_s_Nam=AgnesJones Type = Sternwheel Steamboat Type = Scow schooner RegNo = RegNo = Year Built=1883 Year Built=0 Year _Sunk 1920 Year—Sunk= 1889 Date_Sunk=111811920 Date— Sunk-Cause = Burned Cause = Burned Owner= , owner= Captain = Captain = Length = Length = Beam= Beam = Tonnage = 324 Tonnage Engine = Engine = sail County = Sonoma County= Sonoma State 1,Yate = State_4^: ate = Latitude= 38deg 14'01;'N Latitude = 38deg 14'08'!d Longitude=122deg 38'15W Longitude=122deg 38`15'1 DecLong =-722.638 DecLong =-122.638 Depth:; 0 Depth =0 Quad= Petaluma Quad=Petaluma - Descriptlo = at Petaluma • - Descriptio = at Petaluma LocRadius =1000 LocRadius =1000 File_= 0 File _= 0 Comments = Comments = Directions;Td here,- From here Directions: To here -From here State of California — The Natural Resources Agency EDMUND G. BROWN JR., Governor . F. {` DEPARTMENT OF FISH AND GAME CHARLTON H. BONHAM, Director, Bay Delta Region 7329 Silverado Trail v}r Napa, CA 94558 (707) 944-5500 _r U vmj.dfq.ca.gav PUBLIC WORKS July 6, 2012 Ms. Diane Ramirez City of Petaluma 11 English Street Petaluma, CA 94952 Dear Ms. Ramirez: Subject: Trestle Rehabilitation Project, Mitigated Negative Declaration, SCH #2012062036, City of Petaluma, Sonoma County The Department of Fish and Game (DFG) has reviewed the Mitigated Negative Declaration (MND) for the Trestle Rehabilitation Project (Project). The MND was received in our office on June 13, 2012. DFG is identified as a Trustee Agency pursuant to the California Environmental Quality Act (CEQA) Section 15386 and is responsible for the conservation, protection, and management of the State's biological resources. DFG is -submitting comments on the MND as a means to inform the Lead Agency of our concerns regarding sensitive resources which could potentially be affected by the Project. The Project proposes to rehabilitate the Petaluma Trestle, located on the south bank of the Petaluma River, in the City of Petaluma (City), Sonoma County. The MND notes that the Trestle is in a state of decay and disrepair due to weathering and lack of maintenance. The Trestle has been identified in City planning documents as an important component of the downtown waterfront for its historical value and for increasing riverfront uses, activities and development. The rehabilitation will include re -use, repair and replacement of existing timber decking, framing, stringers, bents and piles. In addition to the rehabilitation of the Trestle, the City will implement slope stabilization repairs, install educational features along the waterfront and potentially construct a new pedestrian walkway. It is unclear from reading the Project description if all of the creosote treated piles that would not be reused would be removed from the Project site. Please clarify. In order to minimize in -water impacts, please clarify why the potential staging area is located within the river. DFG recommends minimizing the in -water staging area to the maximum extent feasible and using an upland alternative location. Please also clarify how the creosote piles would be wrapped or sealed within the channel. Conserving CaCfornia's W- ifdCfe Since 1870 Ms. Diane Ramirez July 6, 2012 Page 2 Longfin smelt Recent surveys by DFG staff identified longfin smelt (state threatened) utilizing the tidally influenced areas of the Petaluma River, which is within the Project area. Longfin smelt are especially susceptible to the sound energy produced during pile driving activities; criterion to prevent take limits the Sound Exposure Level (SEL) to 183 dB. According to the MND, peak noise levels are expected to fall between 170 to 180 dB, but the Project does not include hydroacoustic monitoring to ensure that a 183 dB SEL is not being exceeded. Therefore, use of an impact hammer to drive piles should be limited to a work period of July 1 to September 30. During this time period, water temperature and salinity levels preclude longfin smelt from utilizing the Project area. Impact hammer driving outside this time period without monitoring and additional sound attenuation measures is likely to result in take of longfin smelt. A vibratory hammer or another pile driving mechanism does not have to be limited to this time period. Bird Survey Before Commencement of Project Activities If Project activities are scheduled during the nesting season of protected raptors and migratory birds, February 15 to August 15, a focused survey for active nest of such birds should be conducted by a qualified biologist within 15 days prior to the beginning to Project - related activities. The results of the survey should be recorded and made available to DFG and U.S. Fish & Wildlife Service (USFWS) upon request. If an active nest is found, the Project proponent should consult with DFG and USFWS regarding appropriate action to comply with the Migratory Bird Treaty Act of 1918 and the Fish and Game Code. If a lapse in Project -related work of 15 days or longer occurs, another focused survey and if needed, consultation with DFG and USFWS, should be required before Project work can be reinitiated. California Endangered Species Act Please be advised that a California Endangered Species Act (CESA) Permit must be obtained if the Project has the potential to result in take of species of plants or animals listed under CESA, either during construction or over the life of the Project. Issuance of a CESA Permit is subject to CEQA documentation. Therefore, the CEQA document must specify impacts, mitigation measures, and a mitigation monitoring and reporting program. If the Project will impact CESA listed species, early consultation is encouraged, as significant modification to the Project and mitigation measures may be required in order to obtain a CESA Permit. Lake and Streambed Alteration Agreement For any activity that will divert or obstruct the natural flow, or change the bed, channel, or bank (which may include associated riparian resources) of a river or stream, or use material from a streambed, DFG may require a Lake and Streambed Alteration Agreement (LSAA), pursuant to Section 1600 et seq. of the Fish and Game Code, with the applicant. Issuance of an LSAA is subject to CEQA. DFG, as a responsible agency under CEQA, will consider the CEQA document for the project. The CEQA document should fully identify the potential impacts to the stream or riparian resources and provide adequate avoidance, mitigation, monitoring and reporting commitments for completion of the agreement. To obtain Ms.. Diane Ramirez July 6, 2012 Page 3 information about the LSAA notification process, please access our website at http:/IwvpN.dfq,ca.gov/habcon/16001 or to request a notification package, contact the Lake and Streambed Alteration Program at (707) 944-5520. DFG appreciates the opportunity to comment on the Trestle Rehabilitation Project. DFG staff is available to meet with you to further clarify our comments and provide technical assistance on any changes necessary to protect resources. if you have any questions, please contact Mr. Adam McKannay, Environmental Scientist, at (707) 944-5534; or Ms. Karen Weiss, Senior Environmental Scientist, at (707) 944-5525. Sincerely, Scott Wilson Acting Regional Manager Bay Delta Region cc: State Clearinghouse STATE OF CALIFORNIA PUBLIC UTILITIES COMMISSION 933 VAN NESS AVENUE SAN FRANCISCO, CA 74102.3256 June 19, 2012 Diane Ramirez City of Petaluma 11 English Street Petaluma, CA 94952 EDMUND G. BROWN JR., Govemor JUS! � 5 2011 PUBLIC WORKS Re; Notice of Completion & Environmental Document Transmittal SC1-I 9 2012062036 - City of Petaluma Trestle Rehabilitation Project Deur Ms. Ramirez: As the state agency responsible for rail safety within California, the California Public Utilities Commission (CPUC or Cormnission) recommends that development projects proposed near rail corridors be planned with the safety of these corridors in mind. New deNrelopmerns and improvements to existing facilities may incre=ase vehicular traffic volumes, not only on streets and at intersections, but also at at -grade highway -rail crossings, In addition, projects may increase pedestrian traffic at crossings, and elsewhere along rail corridor rights-of-way, Working with CPUC staff early in project planting will help project proponents, agency staff, and other reviewers to identify° potential project impacts and appropriate mitigation measures, and thereby improve the safety of motorists, pedestrians, railroad personnel, and railroad passengers. We recon mnend that the City incorporate any improvernents to the at -grade railroad crossings and rail corridors into the existing City mitigation fee program to ensure that improvements get programmed with an actual funding mechanism. This will also address project specific and cumulative impacts of new development projects to rail facilities, Otherwise, the burden could eventually fall on one project or the City, depending on time level of significance and or safety concerns. This could potentially alfect the entitlement process for future. development projects according to CEQ A. Thant: you for your consideration of these comments. If you have any questions in this matter, please contact me at (916) 928-2515 or email at annl,`�cpuc;cLgoy. Side rely, David Stewart ► - Utilities Engineer Consumer Protection and Safety Division Rail Transit and Crossings Branch 180 Promenade Circle, Suite 115 Sacrarrme to, CA 95834 RECEHVE[D) ,JUN 2 6 z012 PUBLIC WORKS June 21, 2012 Diane Ramirez Project Manager City of Petaluma Public Works 11 English Street Petaluma, CA 94952 Dear Diane, Thank you so much for notifying me that the Petaluma Yacht Club was left off the list of stake holders for the Trestle Rehabilitation Project. Please consider this a formal request to add The Petaluma Yacht Club to any correspondence that concerns the Trestle. After reading The CEQA Environmental Assessment and Initial Study document proposing a Mitigated Negative Declaration for the Downtown Trestle Rehabilitation Project we have concluded that further considerations of impacts is essential. The report seems incomplete as there was not much real research reported on the impact to Commerce and Recreation. The Petaluma Yacht Club was never contacted in an effort to gather information. The Petaluma Yacht Club would like a few issues explored further before supporting this project. 1) We believe that the commercial effects that losing 30-60 visiting yachts on weekends between the months of April to October would have on the downtown merchants, restaurant owners, and The Petaluma Yacht Club has been under estimated as "Less than Significant with Mitigation" in the report. We believe that these should have been rated as potentially significant impacts that need to be examined and mitigated. The Petaluma Yacht club is dependent on visiting Yacht Clubs for the majority of its annual operating budget. These Yacht Clubs also come with day or evening visitors by car and other club members utilize local camp grounds and hotels. These clubs sometimes rent out whole restaurants for an evening and many boaters eat every meal out for 3-4 days. The economic impact created by this activity can be substantial to local businesses. 2) The Petaluma Yacht Club has leased the property at 10 C St. from the City since 1984. This area is described in our lease as "located at the north end of First Street, and bound by the Petaluma River and Sonoma County Assessor's Parcel Nos. 8-067-01, 8-067-03, by C Street and the Petaluma River". As such the club has utilized the entire property for more than 25 years as a both an entrance to the building on the premises and an entrance to the docks. We request that a mutually acceptable agreement be entered into if we all agree that the club property will be utilized to accommodate the proposed project. 3) The proposal to install temporary docks is incomplete. The areas proposed in the Assessment would not be logical due to the shallow river depths unless dredging was also provided. There is also no mention of the availability of water and power to the temporary docks. The report does not mention that the visiting yachts are between 34- 55 feet long with a beam of 13-16 ft. so the proposed temporary dock space is very constraining when you have sail boats and larger yachts that may have to park opposite the barges in the construction area. The Petaluma Yacht Club requests that a more complete proposed mitigation is explored. 4) We would also like more information of the effects of noise and vibration on nearby buildings as well as birds and fish. Thank you for your time in considering our issues. We treasure our access to downtown by way of water and have the good of the City of Petaluma in mind as do the project leaders. Man thanks again, nda Blue Commodore Petaluma Yacht Club Copy: Iry Piotrkowski, Esq. • 4 a 0