August 11, Subject: Zanja Trail and Greenway Park Project Design Constraints and Jurisdictional Resources

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1 HELIX Environmental Planning, Inc El Cajon Boulevar Suite 200 La Mesa, CA tel fax SDG-16 Mr. Chris Tiffany Schmit Design Group, Inc th Avenue, Suite 500 San Diego, CA Subject: Zanja Trail an Greenway Park Project Design Constraints an Jurisictional Resources Dear Mr. Tiffany: HELIX Environmental Planning, Inc. (HELIX) has prepare this brief cover letter to summarize existing biological conitions an associate esign constraints within the Project Stuy Area (PSA) for the Zanja Trail an Greenway Park Project. Per project information provie to HELIX by Schmit Design Group, Inc., the Zanja Trail an Greenway Park Project will establish a natural surface trail along or near the historic Mill Creek Zanja between 9 th Street in Downtown an Wabash Avenue, the eastern most City of bounary. Inclue will be one gateway at the west en, four pocket parks, an amenities such as interpretive signage along the route as esigne. Zanja Trail an Greenway Park will connect with the Orange Blossom Trail, which connects with the Santa Ana River Trail. When complete, this trail network will loop continually through north City of an into the Crafton Hills. Per the Zanja Trail Alignment exhibit provie to HELIX by Schmit Design Group, Inc. on July 23, 2015, the propose trail woul parallel the north sie of Mill Creek Zanja between 9 th Street an Church Street, roughly follow the south sie of Mill Creek Zanja between Church Street east to Grove Street, then turn south an coincie with the Orange Blossom Trail east to Lincoln Street, again paralleling the south sie of Mill Creek Zanja between Lincoln Street east to Dearborn Street, an then paralleling the north sie of Mill Creek Zanja east to Wabash Avenue. No peestrian crossings of the zanja are shown on this exhibit.

2 Letter Report to Mr. Chris Tiffany Page 2 of 4 METHODS HELIX conucte vegetation mapping an a jurisictional elineation within the PSA on July 28, The PSA consists of an approximately 100-foot-wie corrior centere along the propose Zanja Trail an a potential alternate route between Grove an Lincoln Streets, as well as following the limits of propose pocket parks an potential park expansion. Please refer to the enclose jurisictional elineation report for mapping methoology. In aition, searches of the California Department of Fish an Willife (CDFW) California Natural Diversity Database (CNDDB) an U.S. Fish an Willife Service (USFWS) sensitive species atabase were conucte to obtain information regaring sensitive species known to occur within the vicinity of the PSA. Sensitive species are those that have been given special recognition by feeral, state, or local government agencies an organizations because of limite, eclining, or threatene populations. Focuse surveys for rare plants an liste or sensitive animal species were not conucte. RESULTS The vast majority of the PSA consists of urban/evelope lans, incluing existing roas, trails, an parks, as well as isturbe habitat consisting primarily of previously cleare an grae areas with little to no vegetation. Remnant areas of non-native grasslan remain in portions of the PSA. Mill Creek Zanja extens the length of the PSA an is non-vegetate to sparsely vegetate between 9 th Street an Lincoln Street; upstream of Lincoln Street it supports varying extents of isturbe wetlan an riparian habitats. Potential jurisictional resources within the PSA consist of Mill Creek Zanja an associate wetlan an riparian vegetation. Four of the eight vegetation communities mappe in the PSA are potential jurisictional habitats: riparian woolan, riparian scrub (isturbe), freshwater marsh (isturbe), an non-vegetate channel/streambe. Uplan vegetation communities mappe in the PSA inclue non-native grasslan, non-native vegetation, isturbe habitat, an urban/evelope lan. Please refer to the enclose jurisictional elineation report for epictions of vegetation communities an areas of potential U.S. Army of Engineers (USACE), Regional Water Quality Control Boar (RWQCB), an CDFW jurisiction mappe within the PSA (HELIX 2015). No sensitive plant or animal species were observe uring the July 28, 2015 fiel survey. Results of CNDDB an USFWS atabase searches (refer to enclose graphic) inicate recors of three sensitive plant species an six sensitive animal species within one mile of the PSA. Sensitive plant species are not expecte to occur within the PSA ue to existing isturbances, prevalence of non-native plant species, lack of suitable habitat, an general evelope conition of the PSA. The feeral an state liste enangere least Bell s vireo (Vireo bellii pusillus) is not expecte to occur in the PSA as the riparian scrub an woolan habitats are small an isolate, o not

3 Letter Report to Mr. Chris Tiffany Page 3 of 4 support the habitat structure typically use by this species, an are not of sufficient size to support breeing territories. The feeral liste enangere an state species of special concern San Bernarino kangaroo rat (Dipoomys merriami parvus) is not expecte to occur in the PSA as suitable habitat is not present. USFWS critical habitat is not present within the PSA. The nearest critical habitat is locate over one mile to the north along the Santa Ana River (see enclose USFWS Critical Habitat graphic). DISCUSSION AND RECOMMENDATIONS Potential jurisictional resources within the PSA inclue the entire with of Mill Creek Zanja (top of bank to top of bank), three small stans of riparian woolan extening beyon the banks of the zanja (two stans within the University of campus an one stan along the Zanja Trail Alternate Route), an a short reach of tributary channel originating east of Lincoln Street an connecting almost immeiately with the zanja (forming a Y shape area of jurisictional habitat on the east sie of Lincoln Street). As shown on the Zanja Trail Alignment ate July 23, 2015, it appears that the project woul mostly or completely avoi impacts to jurisictional resources. However, HELIX recommens reviewing the propose esign an making revisions, as neee, to ensure impacts to jurisictional resources are avoie an minimize to the greatest extent practicable. Recommenations inclue: Locating the Zanja Trail completely outsie the top of bank of Mill Creek Zanja (ege of non-vegetate channel) an associate riparian woolan extening beyon the banks of the channel. If peestrian crossings of the zanja are propose, constructing clear spanning briges that are seate outsie the limits of CDFW jurisiction an woul not result in fill or other groun isturbance within the jurisictional limits. Such crossings woul not be regulate by the USACE, RWQCB, or CDFW, as they woul not impact jurisictional resources. Confirming that the trail woul follow the existing path through Sylvan Park, or otherwise be site outsie of the limits of Mill Creek Zanja. Confirming sufficient space is available to construct the trail without impacting riparian woolan along Sylvan Boulevar.

4 Letter Report to Mr. Chris Tiffany Page 4 of 4 CONCLUSION The most significant biological constraint affecting the project is the presence of jurisictional resources (i.e., Mill Creek Zanja). Any irect impacts to jurisictional resources woul be subject to regulation by the USACE, RWQCB, an/or CDFW. Impacts to USACE jurisictional areas woul require a Clean Water Act (CWA) Section 404 permit from the USACE an a CWA Section 401 Water Quality Certification from the RWQCB. Impacts to CDFW jurisictional areas woul require a California Fish an Game Coe Section 1602 Streambe Alteration Agreement from CDFW. It shoul be note that in aition to regulating impacts to feeral jurisictional areas (i.e., Waters of the U.S.), the RWQCB may also regulate impacts to CDFW habitat outsie the limits of feeral jurisiction as impacts to waters of the state. If impacts cannot be avoie, mitigation an other permit conitions woul be negotiate uring the permit process. If the project can be esigne to avoi impacts to the zanja by locating the trail outsie of the limits of jurisictional resources (incluing clear span briges of any peestrian crossings), then wetlan permits from the USACE, RWQCB, an CDFW woul not be require, thereby greatly simplifying the project approval process as it relates to biological resources. Please let me or Tom Huffman know if you have any questions. Sincerely, Stacy Nigro Senior Scientist Enclosures: CNDDB an USFWS Species (Database Recors) USFWS Critical Habitat REFERENCES California Department of Fish an Willife (CDFW). California Natural Diversity Data Base (CNDDB) RareFin Database Program, Version 5. HELIX Environmental Planning, Inc Jurisictional Delineation Report for the Zanja Trail an Greenway Park Project. August 7. Schmit Design Group, Inc Propose Trail Alignment Exhibit for the Zanja Trail an Greenway Park Project. July 23.

5 Project Stuy Area Airport CNDDB California satintail (Imperata brevifolia) Parish's gooseberry (Ribes ivaricatum) Coast horne lizar (Phrynosoma coronatum) Least Bell's Vireo (Vireo bellii pusillus) Palli bat (Antrozous pallius) San Bernarino Avenue Slener-horne Spineflower (Doecahema leptoceras) Western yellow bat (Lasiurus xanthinus) USFWS San Bernarino kangaroo rat (Dipoomys merriami parvus) Coastal California gnatcatcher (Polioptila californica californica) University of 9th Street Colton Avenue High School Citrus Avenue l Re $ "! s an Bo Wabash Avenue Church Street A.T.& S.F. I:\PROJECTS\S\SDG\SDG-16_ZanjaTrail\Map\JDR\CNDDB_USFWS.mx SDG /31/15 -EV Downtown Juson Street Lugonia Avenue v ule ar gh Hi en Av la n ue CNDDB & USFWS Species ZANJA TRAIL AND GREENWAY PARK PROJECT N 0 2,000 Feet

6 Santa An a Rive r Airport San Bernarino Avenue University of 9th Street Colton Avenue A.T.& S.F. High School Citrus Avenue Wabash Avenue Church Street Downtown Juson Street Lugonia Avenue l Re $ "! sb I:\PROJECTS\S\SDG\SDG-16_ZanjaTrail\Map\JDR\CriticalHabitats.mx SDG /31/15 -EV an ou ar lev gh Hi lan nu ve A e Project Stuy Area Santa Ana Sucker Critical Habitat San Bernarino Kangaroo Rat Critical Habitat Critical Habitats ZANJA TRAIL AND GREENWAY PARK PROJECT N 0 2,500 Feet

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