HomeMy WebLinkAboutAppendix B - Biological Resources Assessment
2201 N. Grand Avenue #10098 | Santa Ana, CA 92711-0098 | (714) 716-5050
www.ELMTConsulting.com
February 6, 2026
LEWIS MANAGEMENT CORP
Attention: Stacey Sassaman
1156 North Mountain Avenue
Upland, CA 91786
SUBJECT: Biological Resources Assessment for The Resort at the Arboretum Project Located in
the City of Fontana, San Bernardino County, California
Introduction
This report contains the findings of ELMT Consulting’s (ELMT) biological resources assessment for The
Resort at the Arboretum Project (project site or site) located in the City of Fontana, San Bernardino County,
California. The field investigation was conducted on December 12, 2025, to document baseline conditions
and assess the potential for special-status 1 plant and wildlife species to occur within the project site that
could pose a constraint to implementation of the proposed project. Special attention was given to the
suitability of the project site to support burrowing owl (Athene cunicularia), San Bernardino kangaroo rat
(Dipodomys merriami parvus), California gnatcatcher (Polioptila californica californica), and other
special-status plant and wildlife species identified by the California Department of Fish and Wildlife’s
(CDFW) California Natural Diversity Database (CNDDB), and other electronic databases as potentially
occurring in the general vicinity of the project.
Additionally, the report also addresses resources protected under the Migratory Bird Treaty Act (MBTA)
and California Fish and Game Code (FGC), federal Clean Water Act (CWA) regulated by the United States
Army Corps of Engineers (Corps) and Regional Water Quality Control Board (Regional Board)
respectively, and Section 1602 of the FGC administered by CDFW.
Project Location
The project site is generally located south and east of Interstate 15, north of State Route 210, and west of
Interstate 215 in the City of Fontana, San Bernardino County, California. The site is depicted on the Devore
quadrangle of the United States Geological Survey’s (USGS) 7.5-minute map series within Section 18 of
Township 1 North, Range 5 West. Specifically, the project site is roughly bounded to the east by Sierra
Avenue and to the south of Duncan Canyon Road, and east and south of Interstate 15 within Assessor’s
Parcel Number 0239-081-06, -11, -15, -16, -18, -19, -36, -40, -41, -42, -43, -51, -52, and -53. Refer to
Exhibits 1-3 in Attachment A.
1 As used in this report, “special-status” refers to plant and wildlife species that are federally and State listed, proposed, or
candidates; plant species that have been designated with a California Native Plant Society Rare Plant Rank; wildlife species that
are designated by the CDFW as fully protected, species of special concern, or watch list species; and specially protected natural
vegetation communities as designated by the CDFW.
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Methodology
A literature review and records search were conducted to determine which special-status biological
resources have the potential to occur on or within the general vicinity of the project site. In addition to the
literature review, a general habitat assessment or field investigation of the project site was conducted to
document existing conditions and assess the potential for special-status biological resources to occur within
the project site.
Literature Review
Prior to conducting the field investigation, a literature review and records search was conducted for special-
status biological resources potentially occurring on or within the vicinity of the project site. Previously
recorded occurrences of special-status plant and wildlife species and their proximity to the project site was
determined through a query of the CDFW’s QuickView Tool in the Biogeographic Information and
Observation System (BIOS), CNDDB Rarefind 5, the California Native Plant Society’s (CNPS) Electronic
Inventory of Rare and Endangered Vascular Plants of California, Calflora Database, compendia of special-
status species published by CDFW, and the United States Fish and Wildlife Service (USFWS) species
listings.
All available reports, survey results, and literature detailing the biological resources previously observed
on or within the vicinity of the project site was reviewed to understand existing site conditions and note the
extent of any disturbances that have occurred within the project site that would otherwise limit the
distribution of special-status biological resources. Standard field guides and texts were reviewed for specific
habitat requirements of special-status and non-special-status biological resources, as well as the following
resources:
• Google Earth Pro historic aerial imagery (1985-2025);
• United States Department of Agriculture (USDA) Natural Resource Conservation Service (NRCS),
Soil Survey 2;
• USFWS Critical Habitat designations for Threatened and Endangered Species; and
• USFWS Endangered Species Profiles.
The literature review provided a baseline from which to inventory the biological resources potentially
occurring within the project site. The CNDDB database was used, in conjunction with ArcGIS software, to
locate the nearest recorded occurrences of special-status species and determine the distance from the project
site.
Field Investigation
Following the literature review, biologist Megan E. Peukert inventoried and evaluated the condition of the
habitat within the project site on December 12, 2025. Plant communities and land cover types identified on
aerial photographs during the literature review were verified by walking meandering transects throughout
the project site. In addition, aerial photography was reviewed prior to the site investigation to locate
2 A soil series is defined as a group of soils with similar profiles developed from similar parent materials under comparable climatic
and vegetation conditions. These profiles include major horizons with similar thickness, arrangement, and other important
characteristics, which may promote favorable conditions for certain biological resources.
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potential natural corridors and linkages that may support the movement of wildlife through the area. These
areas identified on aerial photography were then walked during the field investigation.
Soil Series Assessment
On-site and adjoining soils were researched prior to the field investigation using the USDA NRCS Soil
Survey for San Bernardino County, California. In addition, a review of the local geological conditions and
historical aerial photographs was conducted to assess the ecological changes that the project site has
undergone.
Plant Communities
Plant communities were mapped using 7.5-minute USGS topographic base maps and aerial photography.
The plant communities were classified in accordance with Sawyer, Keeler-Wolf and Evens (2009),
delineated on an aerial photograph, and then digitized into GIS Arcview. The Arcview application was used
to compute the area of each plant community and/or land cover type in acres.
Plants
Common plant species observed during the field investigation were identified by visual characteristics and
morphology in the field and recorded in a field notebook. Unusual and less-familiar plants were
photographed in the field and identified in the laboratory using taxonomic guides. Taxonomic nomenclature
used in this study follows the 2012 Jepson Manual (Hickman 2012). In this report, scientific names are
provided immediately following common names of plant species (first reference only).
Wildlife
Wildlife species detected during the field investigation by sight, calls, tracks, scat, or other sign were
recorded during surveys in a field notebook. Field guides used to assist with identification of wildlife
species during the survey included The Sibley Field Guide to the Birds of Western North America (Sibley
2003), A Field Guide to Western Reptiles and Amphibians (Stebbins 2003), and A Field Guide to Mammals
of North America (Reid 2006). Although common names of wildlife species are well standardized,
scientific names are provided immediately following common names in this report (first reference only).
Jurisdictional Drainages and Wetlands
Aerial photography was reviewed prior to conducting a field investigation in order to locate and inspect
any potential natural drainage features, ponded areas, or water bodies that may fall under the jurisdiction
of the United States Army Corps of Engineers (Corps), Regional Water Quality Control Board (Regional
Board), or CDFW. In general, surface drainage features indicated as blue-line streams on USGS maps that
are observed or expected to exhibit evidence of flow are considered potential riparian/riverine habitat and
are also subject to state and federal regulatory jurisdiction. In addition, ELMT reviewed jurisdictional
waters information through examining historical aerial photographs to gain an understanding of the impact
of land-use on natural drainage patterns in the area. The USFWS National Wetland Inventory (NWI) and
Environmental Protection Agency (EPA) Water Program “My Waters” data layers were also reviewed to
determine whether any hydrologic features and wetland areas have been documented on or within the
vicinity of the project site.
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Existing Site Conditions
The proposed project site is located in an area that historically supported undeveloped, vacant land and
natural plant communities. The surrounding area has undergone significant urbanization in recent decades
and development surrounding the project site is primarily residential. At present, the site is bounded to the
east by Sierra Avenue, with residential development beyond; to the north by undeveloped, vacant land with
Interstate 15 beyond; to the west by undeveloped, vacant land; and to the south by Duncan Canyon Road
with residential land beyond. The site itself supports a mix of undeveloped, vacant land that has been
impacted by anthropogenic disturbances associated with on-site and surrounding development and
vehicular access. These on-site disturbances exist densely in the central and southern portions of the project
site. The undisturbed to marginally disturbed portions of the project site support native plant communities.
Topography and Soils
On-site elevation ranges from approximately 1,810 to 1,900 feet above mean sea level and slopes
marginally from north south. On-site topography is generally flat but contains small berms and depressions
throughout. Based on the NRCS USDA Web Soil Survey, the project site is underlain by Soboba stony
loamy sand (2 to 9 percent slopes) and Soboba gravelly loamy sand (0 to 9 percent slopes). Soils on-site
are generally very rocky.
Vegetation
The project site supports one (1) plant community: chamise chaparral. In addition, the site supports two (2)
land cover types that would be classified as disturbed and developed (refer to Exhibit 4, Vegetation, in
Attachment A). Refer to Attachment B, Site Photographs, for representative site photographs.
The majority of the undisturbed areas of the project site support a chamise chaparral plant community. The
chamise chaparral plant community is dominated by chamise (Adenostoma fasciculatum) and contains other
native chaparral species such as California buckwheat (Eriogonum fasciculatum), common sunflower
(Helianthus annus), chia (Salvia hispanica), white sage (Salvia apiana), California sagebrush (Artemesia
californica), heliotrope (Phacelia sp.), hairy horsebrush (Tetradymia comosa), and deerweed (Acmispon
glaber).
Disturbed land occurs within the central and southern portions of the site as well as along site boundaries,
in association with unpaved access roads, cleared vegetation for active construction, as well as a water
detention basin. Vegetative cover in these areas range from barren to sparse. Representative plant species
in disturbed areas onsite include redstem filaree (Erodium cicutarium), Mediterranean mustard
(Hirschfeldia incana), ripgut brome (Bromus diandrus), red brome (Bromus madritensis), barley (Hordeum
sp.), tree tobacco (Nicotiana glauca), yellow star-thistle (Centaurea solstitialis), and purple fountain grass
(Pennisetum setaceum rubrum).
Developed land occurs in the south eastern portion of the site in the form of a asphalt pad used for the on-
site construction mobile office trailer and parking.
Wildlife
Plant communities provide foraging habitat, nesting/denning sites, and shelter from adverse weather or
predation. This section provides a discussion of those wildlife species that were observed or are expected
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to occur within the project site. The discussion is to be used a general reference and is limited by the season,
time of day, and weather conditions in which the field investigation was conducted. Wildlife detections
were based on calls, songs, scat, tracks, burrows, and direct observation. The project site provides limited
habitat for wildlife species except those adapted to a high degree of anthropogenic disturbances and
development.
Fish
No fish or hydrogeomorphic features (e.g., creeks, ponds, lakes, reservoirs) with frequent sources of water
that would support populations of fish were observed on or within the vicinity of the project site. Therefore,
no fish are expected to occur and are presumed absent from the project site.
Amphibians
No amphibians or hydrogeomorphic features (e.g., perennial creeks, ponds, lakes, reservoirs) that would
provide suitable habitat for amphibian species were observed on or within the vicinity of the project site.
Therefore, no amphibians are expected to occur and are presumed absent from the project site.
Reptiles
The project site provides suitable foraging and cover habitat for a limited variety of local reptile species
adapted to moderate anthropogenic disturbance. Reptilian species observed onsite include side blotched
(Uta stansburiana), western fence lizard (Sceloporus occidentalis) and coachwhip (Masticophis flagellum).
Birds
The project site and surrounding area provide suitable foraging and nesting habitat for a variety of local
bird species. Bird species detected during the field investigation include California towhee (Melozone
crissalis), northern mockingbird (Mimus polyglottos), lesser goldfinch (Spinus psaltria), Say’s phoebe
(Sayornis saya), American crow (Corvus brachyrhynchos), and Lazuli bunting (Passerina amoena).
Mammals
The project site provides suitable foraging and cover habitat for a mammalian species adapted to a moderate
degree of anthropogenic disturbance. The only mammalian species observed during the investigation was
San Diego black-tailed jackrabbit (Lepus californicus bennettii). Additional common mammalian species
that could be expected to occur onsite include coyote (Canis latrans), and desert cottontail (Sylvilagus
audubonii).
Nesting Birds
No active avian nests or birds exhibiting nesting behavior were observed during the field investigation,
which was conducted outside of breeding season. The project site and surrounding area provide suitable
foraging habitat and nesting opportunities for a variety of year-round and seasonal avian residents, as well
as migrating songbirds that could occur in the area. In addition, the project site has the potential to provide
suitable nesting opportunities for birds that nest on the open ground. Raptors are not expected to nest on-
site due to the lack of suitable nesting opportunities.
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Nesting birds are protected pursuant to the Migratory Bird Treaty Act (MBTA) and California Fish and
Game Code (Sections 3503, 3503.5, 3511, and 3513 prohibit the take, possession, or destruction of birds,
their nests or eggs). If construction occurs between February 1st and August 31st, a pre-construction
clearance survey for nesting birds should be conducted within three (3) days of the start of any vegetation
removal or ground disturbing activities to ensure that no nesting birds will be disturbed during construction.
Migratory Corridors and Linkages
Habitat linkages provide connections between larger habitat areas that are separated by development.
Wildlife corridors are similar to linkages but provide specific opportunities for animals to disperse or
migrate between areas. A corridor can be defined as a linear landscape feature of sufficient width to allow
animal movement between two comparatively undisturbed habitat fragments. Adequate cover is essential
for a corridor to function as a wildlife movement area. It is possible for a habitat corridor to be adequate for
one species yet still inadequate for others. Wildlife corridors are features that allow for the dispersal,
seasonal migration, breeding, and foraging of a variety of wildlife species. Additionally, open space can
provide a buffer against both human disturbance and natural fluctuations in resources.
According to the San Bernardino Open Space, the project site is not mapped as occurring within or adjacent
to any Major Open Space Areas. The nearest Major Open Space Areas are the Cajon Wash, located
approximately 0.88 miles to the northeast, and Duncan Canyon, which occurs in the foothills of the San
Gabriel Mountains approximately 0.94 miles to the northwest. The project site is comprised of undeveloped,
vacant land, and additional adjacent undeveloped space occurs to the northwest and northeast in between
the project site and the aforementioned Major Open Space Areas. Although historically, these areas would
have once provided useful steppingstone habitat, they are now degraded and fragmented by existing
development and disturbances. Additionally, there are no riparian corridors, creeks, or useful patches of
steppingstone habitat (natural areas) within or connecting the project site to these, or any other, identified
wildlife corridors or linkages. As a result, implementation of the proposed project will not disrupt or have
any adverse effects on any migratory corridors or linkages in the surrounding area.
Jurisdictional Areas
There are three key agencies that regulate activities within inland streams, wetlands, and riparian areas in
California. The Corps Regulatory Branch regulates discharge of dredge or fill materials into “waters of the
United States” pursuant to Section 404 of the Clean Water Act (CWA) and Section 10 of the Rivers and
Harbors Act. Of the State agencies, the CDFW regulates alterations to streambed and bank under Fish and
Wildlife Code Sections 1600 et seq., and the Regional Board regulates discharges into surface waters
pursuant to Section 401 of the CWA and the California Porter-Cologne Water Quality Control Act.
No jurisdictional drainage and/or wetland features were observed on the project site during the field
investigation. Further no blueline streams have been recorded on the project site. Therefore, development
of the project will not result in impacts to Corps, Regional Board, or CDFW jurisdiction and regulatory
approvals will not be required.
Special-Status Biological Resources
The CNDDB Rarefind 5 and the CNPS Electronic Inventory of Rare and Endangered Vascular Plants of
California were queried for reported locations of special-status plant and wildlife species as well as special-
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status natural plant communities in the Devore USGS 7.5-minute quadrangle. Only one quadrangle was
queried due to the proximity of the project site to quadrangle boundaries, regional topography, and
surrounding development. The habitat assessment evaluated the conditions of the habitat(s) within the
boundaries of the project site to determine if the existing plant communities, at the time of the survey, have
the potential to provide suitable habitat(s) for special-status plant and wildlife species.
The literature search identified twenty (20) special-status plant species, forty-five (45) special-status
wildlife species, and three (3) special-status plant communities as having the potential to occur within the
Devore 7.5-minute quadrangle. Special-status plant and wildlife species were evaluated for their potential
to occur within the project site based on habitat requirements, availability and quality of suitable habitat,
and known distributions. Species determined to have the potential to occur within the general vicinity of
the project site is presented in Attachment D: Potentially Occurring Special-Status Biological Resources.
Special-Status Plants
According to the CNDDB and CNPS, twenty (20) special-status plant species have been recorded in the
Devore quadrangle (refer to Attachment D). No special-status plant species were observed on-site during
the field investigation. The project site has been subject to anthropogenic disturbances from weed-
abatement and adjacent and surrounding development; the latter of which has removed on-site habitats from
historic hydrological regimes that once shaped the vegetative structure of plant communities in the area.
These disturbances have reduced, if not eliminated, the suitability of the habitat to support special-status
plant species known to occur in the general vicinity of the project site.
Based on habitat requirements for specific special-status plant species, the availability and quality of
habitats needed by each species, and known distributions, it was determined that the project site has a low
potential to support short-joint beavertail (Opuntia basilaris var. brachyclada). It was further determined
that the project site does not have potential to support any additional special-status plant species known to
occur in the vicinity and all are presumed to be absent.
Short-joint beavertail is not State or Federally listed as Threatened or Endangered. Further, the species was
not observed onsite at the time of the investigation. No further surveys are recommended.
Special-Status Wildlife
According to the CNDDB, forty-five (45) special-status wildlife species have been reported in the Devore
quadrangle (refer to Attachment D). Special-status wildlife species observed during the field investigation
include San Diego black-tailed jackrabbit and coast horned lizard. Based on habitat requirements for
specific species and the availability and quality of on-site habitats, it was determined that the proposed
project site also has a high potential to support Cooper’s hawk (Accipiter cooperii) and California horned
lark (Eremophila alpestris acti); a moderate potential to support Bell’s sage sparrow (Artemesiospiza belli
belli); and a low potential to support coastal whiptail (Aspidoscelis tigris steinegeri). It was further
determined that the project site does not have the potential to support any of the other special-status wildlife
species listed in the CNDDB and all are presumed to be absent. None of the aforementioned species are
federally or state listed as endangered or threatened.
Cooper’s hawk is not expected to nest on-site due to the lack of suitable nesting opportunities. California
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horned lark and Bell’s sage sparrow may be expected to nest on-site.
Based on regional significance, the potential occurrence of burrowing owl, San Bernardino kangaroo rat,
and California gnatcatcher within the project site are described in further detail below:
Burrowing Owl
The burrowing owl is currently listed as a California Candidate Endangered Species. It is a grassland
specialist distributed throughout western North America where it occupies open areas with short vegetation
and bare ground within shrub, desert, and grassland environments. Burrowing owls use a wide variety of
arid and semi-arid environments with well-drained, level to gently-sloping areas characterized by sparse
vegetation and bare ground (Haug and Didiuk 1993; Dechant et al. 1999). Burrowing owls are dependent
upon the presence of burrowing mammals (such as ground squirrels) whose burrows are used for roosting
and nesting (Haug and Didiuk 1993). The presence or absence of colonial mammal burrows is often a major
factor that limits the presence or absence of burrowing owls. Where mammal burrows are scarce, burrowing
owls have been found occupying man-made cavities, such as buried and non-functioning drain pipes, stand-
pipes, and dry culverts. Burrowing mammals may burrow beneath rocks and debris or large, heavy objects
such as abandoned cars, concrete blocks, or concrete pads. They also require open vegetation allowing line-
of-sight observation of the surrounding habitat to forage as well as watch for predators.
No burrowing owls or recent sign (i.e., pellets, feathers, castings, or whitewash) were observed during the
field investigation. The project site is primarily vegetated with a fairly dense chamise chaparral plant
community which does not allow for line-of-sight observation favored by burrowing owls. Additionally,
the project site lacks suitable burrows (>4 inches in diameter) capable of providing nesting opportunities.
Based on the results of the field investigation, it was determined that the project site does not have potential
to support burrowing owl and focused surveys are not recommended. However, out of an abundance of
caution, a preconstruction burrowing owl clearance survey shall be conducted prior to development to
ensure burrowing owl remain absent from the project site.
San Bernardino Kangaroo Rat
The San Bernardino kangaroo rat, federally listed as endangered, is one of several kangaroo rat species in
its range. The Dulzura, the Pacific kangaroo rat (Dipodomys agilis) and the Stephens kangaroo rat
(Dipodomys stephensi) occur in areas occupied by the San Bernardino kangaroo rat, but these other species
have a wider habitat range. The habitat of the San Bernardino kangaroo rat is described as being confined
to pioneer and intermediate Riversidean Alluvial Fan Sage Scrub (RAFSS) habitats, with sandy soils
deposited by fluvial (water) rather than Aeolian (wind) processes. Burrows are dug in loose soil, usually
near or beneath shrubs.
The San Bernardino kangaroo rat is one of three subspecies of the Merriam’s kangaroo rat. The Merriam’s
kangaroo rat is a widespread species that can be found from the inland valleys to the deserts. The subspecies
known as the San Bernardino kangaroo, however, is confined to inland valley scrub communities, and more
particularly, to scrub communities occurring along rivers, streams and drainages. Most of the drainages
have been historically altered as a result of flood control efforts and the resulting increased use of river
resources, including mining, off-road vehicle use and road and housing development. This increased use of
river resources has resulted in a reduction in both the amount and quality of habitat available for the San
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Bernardino kangaroo rat. The past habitat losses and potential future losses prompted the emergency listing
of the San Bernardino kangaroo rat as an endangered species (USFWS, 1998a). PCE’s are physical or
biological features essential to the conservation of a species for which its designated critical habitat is based
on. Examples of PCE’s include food, water, space for individual and population growth, cover or shelter,
etc. The PCEs essential to support the biological needs of foraging, reproducing, rearing of young, intra-
specific communication, dispersal, genetic exchange, or sheltering for San Bernardino kangaroo rat are:
1. River, creek, stream, and wash channels; alluvial fans, flood plains, flood benches and terraces; and
historic braided channels that are subject to dynamic geomorphological and hydrological processes;
2. Alluvial sage scrub and associated vegetation such as coastal sage scrub and chamise chaparral
with a moderately open canopy;
3. Soil series consisting of sand, sandy loam, or loam within its geographical range; and
4. Upland areas proximal to flood plains containing suitable habitat (land adjacent to alluvial fan that
provides refugia).
San Bernardino kangaroo rat is known to occur within Lytle Creek. The project site has been generally
removed from the hydrological influences of Lytle Creek since the installation of Interstate 15 and
associated flood control infrastructure since the mid-1900’s, resulting in the on-site RAFSS plant
community no longer exhibiting the dynamic vegetative succession and diversity typical of this plant
community. In addition, the development of extensive residential neighborhood tracts in the mid-1990’s
thoroughly isolated the project site from suitable habitats within downstream portions of Lytle Creek.
The project site supports a chamise chaparral plant community which varies in vegetative density.
Additionally, areas of the project site are disturbed from vehicle access and adjacent development. Field
sign for kangaroo rat, including San Bernardino kangaroo rat, is distinctive and readily noted in the field.
No sign (e.g., San Bernardino kangaroo rat characteristic burrows, dusting baths, and/or tail drags) was
observed during the field investigation. Additionally, the project site no longer is subject to the hydrologic
influence of Lytle Creek due to the channelization of Lytle Creek for flood control purposes.
Based on these conditions, it was determined that the project site does not provide the requisite habitat
elements needed by San Bernardino kangaroo rat to be present. Therefore, it was determined that San
Bernardino kangaroo rat is presumed absent from the project site. No focused surveys are recommended.
California Gnatcatcher
California gnatcatcher is a federally threatened species with restricted habitat requirements, being an
obligate resident of sage scrub habitats that are dominated by California sagebrush. This species generally
occurs below 750 feet elevation in coastal regions and below 1,500 feet inland. According to J. Atwood
and J. Bolsinger (1992), 99% of all California gnatcatcher observations are in areas with elevations below
950 feet. There are reported occurrences of California gnatcatcher at 1,600 feet elevation (500 meters).
California gnatcatcher ranges from Ventura County south to San Diego County and northern Baja
California and is less common in sage scrub with a high percentage of tall shrubs. It prefers habitat with
more low-growing vegetation. California gnatcatchers breed between mid-February and the end of August,
with peak activity from mid-March to mid-May. Population estimates indicate that there are approximately
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1,600 to 2,290 pairs of coastal California gnatcatcher remaining. Declines are attributed to loss of sage
scrub habitat due to development, as well as cowbird nest parasitism.
California gnatcatcher are ground and shrub-foraging insectivores, feeding on small insects and other
arthropods. A California gnatcatcher’s territory is highly variable in size and seems to be correlated with
distance from the coast, ranging from less than 1 ha to over 9 ha. In a 1998 study, biologist Patrick Mock
concluded that California gnatcatcher in the inland region require a larger territory than those on the coast
in order to meet the nutritional requirements needed for survival and breeding.
The Primary Constituent Elements (PCEs)3 essential to support the biological needs of foraging,
reproducing, rearing of young, intra-specific communication, dispersal, genetic exchange, or sheltering for
California gnatcatcher that were surveyed for include:
1. Dynamic and Successional sage scrub Habitats and Associated Vegetation (Diegan Coastal Sage
Scrub, Coastal Sage-Chaparral Scrub, etc.) that provide space for individual and population growth,
normal behavior, breeding, reproduction, nesting, dispersal and foraging; and
2. Non-sage scrub habitats such as chaparral, grassland, and riparian areas, in proximity to sage scrub
habitats have the potential to provide linkages to help with dispersal, foraging and nesting.
The project site ranges in approximate elevation from 1,826 to 1,847 feet above mean sea level, which is
above the known elevational range of California gnatcatcher. Ninety-nine percent of all California
gnatcatcher observations occur below 950 feet above msl. California gnatcatcher’s preferred habitat is
coastal sage scrub dominated by California sage brush. The project site does not support coastal sage scrub
habitat. In addition, the site is isolated from California gnatcatcher occupied coastal sage scrub habitats and
linkage areas in the region by surrounding development. Given the community present onsite, plus the lack
of any observation of California gnatcatcher in north Fontana and isolation of the site due to the recent
development of surrounding properties, it is highly unlikely that the site might support this species.
Therefore, California gnatcatcher is presumed to be absent from the project site. No further surveys are
recommended.
Special-Status Plant Communities
According to the CNDDB, three (3) special-status plant communities have been reported in the Devore
USGS 7.5-minute quadrangle: RAFSS, Southern Riparian Forest, and Southern Sycamore Alder Riparian
Woodland (refer to Attachment D). No special-status plant communities were observed onsite at the time
of the investigation.
Due to recent and historic disturbances associated with surrounding development, the vegetation supported
by the project site does not support characteristics for special-status plant communities to reside.
Critical Habitats
Under the federal Endangered Species Act, “Critical Habitat” is designated at the time of listing of a species
or within one year of listing. Critical Habitat refers to specific areas within the geographical range of a
3 Specific elements of physical and biological features that provide for a species’ life-history process and are essential to the
conservation of the species.
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species at the time it is listed that include the physical or biological features that are essential to the survival
and eventual recovery of that species. Maintenance of these physical and biological features requires special
management considerations or protection, regardless of whether individuals or the species are present or
not. All federal agencies are required to consult with the USFWS regarding activities they authorize, fund,
or permit which may affect a federally listed species or its designated Critical Habitat. The purpose of the
consultation is to ensure that projects will not jeopardize the continued existence of the listed species or
adversely modify or destroy its designated Critical Habitat. The designation of Critical Habitat does not
affect private landowners, unless a project they are proposing is on federal lands, uses federal funds, or
requires federal authorization or permits (e.g., funding from the Federal Highways Administration or a
Clean Water Act Permit from the United States Army Corps of Engineers). If there is a federal nexus, then
the federal agency that is responsible for providing the funding or permit would consult with the USFWS.
In 2002 the USFWS designated Critical Habitat for San Bernardino kangaroo rat, and the project site was
included within the designated area. Subsequently, in 2008 the USFWS reduced the boundaries of their
previously designated Critical Habitat which removed the project site from designation. The lack of the
needed habitat features within the project site, as well as in north Fontana, prompted USFWS to remove
the Critical Habitat designation in this area. Finally, at the beginning of 2011 the original (2002) designated
Critical Habitat was reinstated by a federal district court ruling which overturned the reduced (2008)
designated Critical Habitat.
Currently the project site is located within designated Critical Habitat Unit 2, Lytle Creek/Cajon Wash.
Refer to Exhibit 5, Critical Habitat in Attachment A. However, since the project does not have a federal
nexus, a Section 7 consultation with the USFWS would not be required for loss or adverse modification of
Critical Habitat. If a federal nexus does occur, a Section 7 Consultation will have to be initiated with
USFWS.
Conclusion
Based literature review and field survey, and existing site conditions discussed in this report,
implementation of the project is not expected to have significant impacts on federally or State listed species
known to occur in the general vicinity of the project site. Additionally, the project will have no effect on
designated Critical Habitat, since there is no federal nexus, or regional wildlife corridors/linkages because
none exist within the area. No jurisdictional drainage and/or wetland features were observed on the project
site during the field investigation. No further surveys are recommended. With completion of the
recommendations provided below, no impacts to year-round, seasonal, or special-status avian residents or
special-status species will occur from implementation of the proposed project.
Recommendations
Migratory Bird Treaty Act and Fish and Game Code
In order to ensure impacts to special-status avian species (i.e., Bell’s sage sparrow, California horned lark,
Cooper’s hawk, Costa’s hummingbird, and loggerhead shrike) do not occur from implementation of the
proposed project, a pre-construction nesting bird clearance survey shall be conducted prior to ground
disturbance. With implementation of the pre-construction nesting bird clearance survey, impacts to special-
status avian species will be less than significant and no mitigation will be required.
February 6, 2026
Page 12
The Resort at the Arboretum
Biological Resources Assessment
Nesting birds are protected pursuant to the Migratory Bird Treaty Act (MBTA) and California Fish and
Game Code (Sections 3503, 3503.5, 3511, and 3513 prohibit the take, possession, or destruction of birds,
their nests or eggs). In order to protect migratory bird species, a nesting bird clearance survey should be
conducted prior to any ground disturbance or vegetation removal activities that may disrupt the birds during
the nesting season.
If construction occurs between February 1st and August 31st, a pre-construction clearance survey for nesting
birds should be conducted within three (3) days of the start of any vegetation removal or ground disturbing
activities to ensure that no nesting birds will be disturbed during construction. The biologist conducting the
clearance survey should document a negative survey with a brief letter report indicating that no impacts to
active avian nests will occur. If an active avian nest is discovered during the pre-construction clearance
survey, construction activities should stay outside of a no-disturbance buffer. The size of the no-disturbance
buffer will be determined by the wildlife biologist and will depend on the level of noise and/or surrounding
anthropogenic disturbances, line of sight between the nest and the construction activity, type and duration
of construction activity, ambient noise, species habituation, and topographical barriers. These factors will
be evaluated on a case-by-case basis when developing buffer distances. Limits of construction to avoid an
active nest will be established in the field with flagging, fencing, or other appropriate barriers; and
construction personnel will be instructed on the sensitivity of nest areas. A biological monitor should be
present to delineate the boundaries of the buffer area and to monitor the active nest to ensure that nesting
behavior is not adversely affected by the construction activity. Once the young have fledged and left the
nest, or the nest otherwise becomes inactive under natural conditions, construction activities within the
buffer area can occur.
As part of the nesting bird clearance, it is recommended that a burrowing owl pre-construction clearance
survey be conducted prior to any ground disturbance or vegetation removal activities to ensure that
burrowing owls remain absent from the project site.
Please do not hesitate to contact Tom McGill at (951) 285-6014 or tmcgill@elmtconsulting.com or Travis
McGill at (909) 816-1646 or travismcgill@elmtconsulting.com should you have any questions this report.
Sincerely,
Thomas J. McGill, Ph.D. Travis J. McGill
Managing Director Director
Attachments:
A. Project Exhibits
B. Site Plan
C. Site Photographs
D. Potentially Occurring Special-Status Biological Resources
E. Regulations
Attachment A
Project Exhibits
Attachment B
Site Plan
INTERSTATE15
INTERSTATE10
CALIFORNIA210
CALIFORNIA66
Attachment C
Site Photographs
Attachment C – Site Photographs
Photograph 1: From the northwest corner of the project site, looking east along the northern boundary.
Photograph 2: From the middle of the northern boundary of the project site, looking south.
Attachment C – Site Photographs
Photograph 3: From the northeastern portion of the site looking west along the northern boundary.
Photograph 4: From the northeastern portion of the site looking south along the eastern boundary and
Sierra Avenue.
Attachment C – Site Photographs
Photograph 5: From the southeastern portion of the project site looking west at the on-site development.
Photograph 6: From the southeastern portion of the project site looking west towards the on-site detention
basin.
Attachment C – Site Photographs
Photograph 7: From the southwest portion of the project site looking east along the southern boundary and
Duncan Canyon Road.
Photograph 8: Representative photo of the on-site chamise chaparral plant community.
Attachment C – Site Photographs
Photograph 9: Representative photo of the on-site disturbed land in the central portion of the project site.
Photograph 10: Representative photo of the on-site water detention basin in the southeastern portion of the
project site.
Attachment D
Potentially Occurring Special-Status Biological Resources
Attachment D – Potentially Occurring Special-Status Biological Resources
Table D-1: Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Aimophila ruficeps canescens
southern California rufous-crowned
sparrow
Fed:
CA:
None
WL
canyons. Prefers coastal sage scrub dominated by California
sagebrush (Artemisia californica) but can also be found
breeding in coastal bluff scrub, low-
No
Presumed Absent
The project site lies outside of the
known elevation range for this
species.
Anniella stebbinsi
southern California legless lizard
Fed:
CA:
None
SSC
Occurs primarily in areas with sandy or loose loamy soils
under sparse vegetation of beaches, chaparral, or pine-oak
woodland; or near sycamores, oaks, or cottonwoods that grow
on stream terraces. Often found under or in the close vicinity
of logs, rocks, old boards, and the compacted debris of woodrat
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Aquila chrysaetos
golden eagle
Fed:
CA:
None
FP; WL
except densely forested areas. Favors secluded cliffs with
overhanging ledges and large trees for nesting and cover. Hilly
supported by updrafts is generally preferred to flat habitats.
Deeply cut canyons rising to open mountain slopes and crags
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Ardea alba
great egret
Fed:
CA:
None
None
mountains and deserts. Feeds and rests in fresh, and saline
emergent wetlands, along the margins of estuaries, lakes, and
slow-moving streams, on mudflats and salt ponds, and in
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Ardea herodias
great blue heron
Fed:
CA:
None
None
shallow estuaries and fresh and saline emergent wetlands. Less
common along riverine and rocky marine shores, in croplands, No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Arizona elegans occidentalis
California glossy snake
Fed:
CA:
None
SSC
Occurs in a wide variety of habitat types including open desert,
areas where the soil is loose and sandy which allows for
burrowing.
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
On-site soils do not provide suitable
Artemisiospiza belli belli
Bell's sage sparrow
Fed:
CA:
None
WL chamise. Also found in coastal sage scrub in south of range. No
Moderate
Suitable nesting and foraging habitat
present onsite. However, habitat
onsite is degraded and isolated from
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Aspidoscelis tigris stejnegeri
coastal whiptail
Fed:
CA:
None
SSC
Found in a variety of ecosystems, primarily hot and dry open
areas with sparse foliage such as chaparral, woodland, and
riparian areas.
No
Low
Suitable foraging habitat onsite.
However, onsite habitat is isolated
by existing development and no
observations have been recorded in
the area.
Astur cooperii
Cooper’s hawk
Fed:
CA:
None
WL
Generally found in forested areas up to 3,000 feet in elevation,
especially near edges and rivers. Prefers hardwood stands and
mature forests, but can be found in urban and suburban areas
where there are tall trees for nesting. Common in open areas
during nesting season.
No
High
Suitable foraging habitat is present
within and surrounding the site. No
suitable nesting opportunities are
present. This species is adapted to
urban environments and occurs
Athene cunicularia
burrowing owl
Fed:
CA:
None
CE
in some landscapes highly altered by human activity. Occurs
scrublands characterized by low-No
Presumed Absent
The project site does not provide
line-of-sight foraging opportunities
preferred by burrowing owl.
Further, no suitable burrows (>4
inches in diameter) were observed.
Bassariscus astutus octavus
southern California ringtail
Fed:
CA:
None
FP
most common at elevations ranging from sea level to 1400 m.
Found in a variety of habitats, they prefer habitats with rocky
outcroppings, canyons, or talus slopes and can be found in
semi-arid country, deserts, chaparral, oak woodlands, pinyon
pine woodlands, juniper woodlands, montane conifer forests,
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Batrachoseps gabrieli
San Gabriel slender salamander
Fed:
CA:
None
None
the Mt. Baldy area of Los Angeles County and the western end
of the San Bernardino Mountains in San Bernardino Co., with
an elevation range of 1,200 - 5,085 feet. Occurs on talus slopes
surrounded by a variety of conifer and montane hardwood
species, including bigcone spruce, pine, white fir, incense
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Bombus crotchii
Crotch bumble bee
Fed:
CA:
None
CE
California east towards the Sierra-Cascade Crest and can be
found uncommonly in western Nevada and south through Baja
California. Inhabits grassland and scrub habitats in hotter and
drier climates than most other bumblebee species and is only
capable of tolerating a narrow range of climatic conditions.
Feeds on a variety of annual and perennial plant species,
classifying it as a dietary generalist. This species usually nests
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Bombus pensylvanicus
American bumble bee
Fed:
CA:
None
None
Nests below grass or underground. Feeds on pollen of a wide No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Buteo regalis
ferruginous hawk
Fed:
CA:
None
WL
found in sagebrush flats, desert scrub, low foothills, or along
the edges of pinyon-juniper woodland. Feeds primarily on
small mammals and typically found in agricultural or open
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Calypte costae
Costa’s hummingbird
Fed:
CA:
None
None
desert hummingbird that breeds in the Sonoran and Mojave
Deserts. Departs desert heat moving into chaparral, scrub, and No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Chaetodipus fallax fallax
northwestern San Diego pocket
mouse
Fed:
CA:
None
None
Mexico, and northern Baja California, from sea level to at least
1,400 meters above msl. Found in a variety of temperate
habitats ranging from chaparral and grasslands to scrub forests
and deser
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
On-site soils do not provide suitable
burrowing conditions.
Chaetodipus fallax pallidus
pallid San Diego pocket mouse
Fed:
CA:
None
None
Occurs in sandy herbaceous areas, usually in association with
rocks or coarse gravel in desert wash, desert scrub, desert
succulent scrub, and pinyon-juniper communities.
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
On-site soils do not provide suitable
Circus hudsonius
northern harrier
Fed:
CA:
None
SSC
Frequents meadows, grasslands, open rangelands, desert sinks,
fresh and saltwater emergent wetlands; seldom found in
wooded areas. Mostly found in flat, or hummocky, open areas
of tall, dense grasses moist or dry shrubs, and edges for
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Dipodomys merriami parvus
San Bernardino kangaroo rat
Fed:
CA:
END
CE;
SSC
sandy loam soils, alluvial fans and flood plains, and along
washes with nearby sage scrub. May occur at lower densities
in Riversidian upland sage scrub, chaparral and grassland in
uplands and tributaries in proximity to Riversidian alluvial fan
sage scrub habitats. Tend to avoid rocky substrates and prefer
No
Presumed Absent
The historical RAFSS within the
project site has degraded
significantly and has been isolated
from surrounding hydrological
influences for several decades and
Dipodomys simulans
Dulzura kangaroo rat
Fed:
CA:
None
None Riversidean alluvial fan sage scrub, and peninsular juniper
woodland habitats.
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
On-site soils do not provide suitable
Elanus leucurus
white-tailed kite
Fed:
CA:
None
FP
habitats, agricultural areas, wetlands, and oak woodlands.
Uses trees with dense canopies for cover. Important prey item No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Empidonax traillii extimus
Southwestern willow flycatcher
Fed:
CA:
END
END
of deciduous trees and shrubs, especially willows or along
woodland edges. Often near streams or marshes. Winters
around clearings and second growth in the tropics, especially
No
Presumed Absent
No suitable habitat is present within
or adjacent to the project site.
Eremophila alpes tris actia
California horned lark
Fed:
CA:
None
WL
fields, or similar habitat types along the coast or in deserts.
Trees are shrubs are usually scarce or absent. Generally rare in
montane, coniferous, or chaparral habitats. Forms large flocks
No
High
Suitable foraging habitat is present
within and surrounding the project
site.
Falco mexicanus
prairie falcon
Fed:
CA:
None
WL
community types. Also occasionally found in open parklands
within coniferous forests. During the breeding season, they are
found commonly in foothills and mountains which provide
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Falco peregrinus anatum
American peregrine falcon
Fed:
CA:
DL
DL
California. Active nesting sites are known along the coast
north of Santa Barbara, in the Sierra Nevada, and in other
mountains of northern California. Breeds mostly in woodland,
forest, and coastal habitats. Riparian areas and coastal and
inland wetlands are important habitats yearlong, especially in
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Icteria virens
yellow-breasted chat
Fed:
CA:
None
SSC
woodlands and thickets of willows, vine tangles, and dense
brush with well-developed understories. Nesting areas are
associated with streams, swampy ground, and the borders of
small ponds. Breeding habitat must be dense to provide shade
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Lanius ludovicianus
loggerhead shrike
Fed:
CA:
None
SSC habitats. Prefers open country with scattered perches for No
Presumed Absent
There is no suitable habitat present
Lepus californicus bennettii
San Diego black-tailed jackrabbit
Fed:
CA:
None
None regions supporting shortgrass habitats. Openness of open No Present
Observed foraging onsite.
Neolarra alba
white cuckoo bee
Fed:
CA:
None
None American southwest near the host plants for Perdita bee No
Presumed Absent
There is no suitable habitat present
Neotoma lepida intermedia
San Diego desert woodrat
Fed:
CA:
None
SSC and San Diego Counties. Prefers moderate to dense canopies, No
Presumed Absent
There is no suitable habitat present
Nyctinomops femorosaccus
pocketed free-tailed bat
Fed:
CA:
None
SSC succulent shrub, desert riparian, desert wash, alkali desert No
Presumed Absent
There is no suitable habitat present
Oncorhynchus mykiss irideus pop.
10
steelhead – southern california DPS
Fed:
CA:
END
CE
Found in permanent coastal streams from San Diego to the
Smith River. No
Presumed Absent
There is no suitable habitat present
Pandion haliaetus
osprey
Fed:
CA:
None
WL
ponderosa pine through mixed conifer habitats. Uses large
trees, snags, and dead-topped trees in open forest habitats for
cover and nesting. Requires open, clear waters for foraging
and uses rivers, lakes, reservoirs, bays, estuaries, and surf
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Perognathus longimembris
brevinasus
Los Angeles pocket mouse
Fed:
CA:
None
SSC
communities in and around the Los Angeles Basin. Prefers
open ground with fine sandy soils. May not dig extensive No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Phrynosoma blainvillii
coast horned lizard
Fed:
CA:
None
SSC
riparian woodland and coniferous forest. In inland areas, this
species is restricted to areas with pockets of open microhabitat,
created by disturbance (i.e. fire, floods, roads, grazing, fire
breaks). The key elements of such habitats are loose, fine soils
with a high sand fraction; an abundance of native ants or other
insects; and open areas with limited overstory for basking and
No Present
Observed onsite during the survey.
Polioptila californica californica
coastal California gnatcatcher
Fed:
CA:
THR
SSC
California sagebrush (Artemisia californica). This species
generally occurs below 750 feet elevation in coastal regions
and below 1,500 feet inland. Ranges from the Ventura County,
south to San Diego County and northern Baja California and it
is less common in sage scrub with a high percentage of tall
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Rana muscosa
southern mountain yellow-legged
frog
Fed:
CA:
END
END;
WL
Occurs in lower elevation habitats characterized by rocky
streambeds and wet meadows, while higher elevation habitats
include lakes, ponds, and streams. Occupy streams in narrow,
rock-
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Rhinichthys osculus ssp. 8
Santa Ana speckled dace
Fed:
CA:
None
SSC
Requires permanent flowing streams within summer water
temperatures of 17 – 20 degrees Celsius. Inhabits shallow
cobble and gravel riffles and small streams that flow through No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Salvadora hexalepis virgultea
coast patch-nosed snake
Fed:
CA:
None
SSC No
Presumed Absent
There is no suitable habitat present
Setophaga petechia
yellow warbler
Fed:
CA:
None
SSC
Mojave Desert region, and high altitudes and the eastern side
of the Sierra Nevada. Winters along the Colorado River and in
parts of Imperial and Riverside Counties. Nests in riparian
areas domina
alders or in mature chaparral. May also use oaks, conifers, and
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Spinus lawrencei
Lawrence’s finch
Fed:
CA:
None
None associated with oaks. Nests in open oak or other arid woodland No
Presumed Absent
There is no suitable habitat present
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Strix occidentalis occidentalis
California spotted owl
Fed:
CA:
None
SSC
and snags, high basal areas of trees and snags, dense canopies,
multiple canopy layers, and downed woody debris. Large old No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Taxidea taxus
American badger
Fed:
CA:
None
SSC
shortgrass prairies, meadows, shrub-steppe communities and
other treeless areas with sandy loam soils where it can dig
more easily for its prey. Occasionally found in open chaparral
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Vireo bellii pusillus
least Bell’s vireo
Fed:
CA:
END
END
feature dense cover within 1-2 meters of the ground and a
southern willow scrub, cottonwood-willow forest, mule fat
scrub, sycamore alluvial woodlands, coast live oak riparian
forest, arroyo willow riparian forest, or mesquite in desert
localities. It uses habitat which is limited to the immediate
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
SPECIAL-STATUS PLANT SPECIES
Ambrosia monogyra
singlewhorl burrobush CA: None
2B.2
Found in sandy soils within chaparral and Sonoran Desert
scrub habitat. Found at elevations ranging from 33 to 1,640 No
Presumed Absent
There is no suitable habitat present
Calochortus plummerae
Plummer's mariposa-lily
Fed:
CA:
CNPS:
None
None
4.2
Prefers openings in chaparral, foothill woodland, coastal sage
scrub, valley foothill grasslands, cismontane woodland, lower
montane coniferous forest and yellow pine forest. Often found
on dry, rocky slopes and soils and brushy areas. Can be very
common after a fire. Found at elevations ranging from 330 to
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Chorizanthe parryi var. parryi
Parry's spineflower
Fed:
CA:
CNPS:
None
None
1B.1
Occurs on sandy and/or rocky soils in chaparral, coastal sage
scrub, and sandy openings within alluvial washes and margins.
Found at elevations ranging from 900 to 4,005 feet. Blooming No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Chorizanthe xanti var. leucotheca
white-bracted spineflower
Fed:
CA:
CNPS:
None
None
1B.2
Found in sandy or gravelly soils within coastal scrub (alluvial
fans), Mojavean desert scrub, pinyon and juniper woodland
habitats. Found at elevations ranging from 984 to 3,937 feet. No
Presumed Absent
There is no suitable habitat present
within the project site.
Cryptantha incana
Tulare cryptantha
Fed:
CA:
CNPS:
None
None
1B.3
Occurs in lower montane coniferous forest (gravelly or rocky).
Found at elevations ranging from 4,692 to 7,054 feet above
msl. Blooming period is from June to August.
No
Presumed Absent
The project site occurs outside of
the known elevation range for this
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Dodecahema leptoceras
slender-horned spineflower
Fed:
CA:
CNPS:
END
END
1B.1
within chaparral and coastal scrub (alluvial fan sage scrub)
habitats. Found at elevations ranging from 655 to 2,495 feet. No
Presumed Absent
There is no suitable habitat present
within the project site.
Eriastrum densifolium ssp.
sanctorum
Santa Ana River woollystar
Fed:
CA:
CNPS:
END
END
1B.1
Ideal habitat appears to be a terrace or bench that receives
overbank deposits every 50 to 100 years. Cryptogamic crusts
are frequently present in occupied areas. Found at elevations
ranging from 299 to 2,001 feet. Blooming period is from April
No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Galium jepsonii
Jepson's bedstraw
Fed:
CA:
CNPS:
None
None
4.3 forest habitats. Found at elevations ranging from 5,052 to No
Presumed Absent
The project site occurs outside of
the known elevation range for this
Galium johnstonii
Johnston’s bedstraw
Fed:
CA:
CNPS:
None
None
4.3 forest habitats. Found at elevations ranging from 5,052 to No
Presumed Absent
The project site occurs outside of
the known elevation range for this
Horkelia cuneata var. puberula
Mesa horkelia
Fed:
CA:
CNPS:
None
None
1B.1
coastal scrub plant communities. Found at elevations ranging
from 230 to 2,657 feet. Blooming period is from February to No
Presumed Absent
There is no suitable habitat present
within or adjacent to the project site.
Juglans californica
southern California black walnut CA: None riparian woodland habitats. Found at elevations ranging from No
Presumed Absent
There is no suitable habitat present
Lilium humboldtii ssp. ocellatum
ocellated humboldt lily
Fed:
CA:
CNPS:
None
None
4.2
coastal scrub, lower montane coniferous forest, and riparian
woodland habitats. Found at elevations ranging from 98 to
5,906 feet in elevation. Blooming period is from March to
No
Presumed Absent
There is no suitable habitat present
within the project site.
Lilium parryi
lemon lily
Fed:
CA:
CNPS:
None
None
1B.2
upper montane coniferous forests, meadows and seeps. Found
at elevations ranging from 4,003 to 9,006 feet. Blooming No
Presumed Absent
The project site occurs outside of
the known elevation range for this
Lycium parishii
Parish's desert-thorn CA: None Found at elevations ranging from 443 to 3,281 feet. Blooming No
Presumed Absent
There is no suitable habitat present
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Malacothamnus parishii
Parish’s bush-mallow
Fed:
CA:
CNPS:
None
None
1A
Species is presumed extinct. Habitats include coastal scrub and
chaparral. Found at elevations ranging from 1,000 to 1,495
feet. Blooming period is from June to July.
No
Presumed Absent
The project site occurs outside of
the known elevation range for this
Monardella saxicola
rock monardella
Fed:
CA:
CNPS:
None
None
4.2
closed-cone coniferous forest, and lower montane coniferous
forest habitats. Found at elevations ranging from 1,640 to No
Presumed Absent
There is no suitable habitat present
within the project site.
Opuntia basilaris var. brachyclada
short-joint beavertail
Fed:
CA:
CNPS:
None
None
1B.2 elevations ranging from 1,394 to 5,906 feet. Blooming period No
Low
Marginal habitat occurs onsite.
However, species was not observed.
Quercus durata var. gabrielensis
San Gabriel oak CA: None at elevations ranging from 1,476 to 3,280 feet. Blooming No
Presumed Absent
There is no suitable habitat present
Senecio astephanus
San Gabriel ragwort CA: None bluff scrub habitats. Found at elevations ranging from 49 to
2,625 feet. Blooming period is from January to April.
No
Presumed Absent
There is no suitable habitat present
Streptanthus bernardinus
Laguna Mountains jewelflower
Fed:
CA:
CNPS:
None
None
4.3
clay or decomposed granite soils. It is sometimes found in
disturbed areas such as streamsides or roadcuts. From 4,724 to
8,202 feet in elevation. Blooming period is from May to
No
Presumed Absent
The project site occurs outside of
the known elevation range for this
species.
Riversidian Alluvial Fan Sage Scrub CDFW Sensitive
Habitat
Occur within broad washes of sandy alluvial drainages that
remain relatively dry through the remainder of the year. Is
substrates that have a dearth of decomposed plant material.
These areas do not develop into riparian woodland or scrub due
floods.
No
Absent
A degraded RAFSS is supported
on-site. Following decades of on-
site disturbances and removal from
local hydrological influences by
surrounding flood control
infrastructure, the site no longer
supports characteristic RAFSS
species richness or vegetative
cover.
Southern Riparian Forest CDFW Sensitive
Habitat cottonwood, and many other wetland plants.
No
Absent
This plant community was not
observed within or adjacent to the
Attachment D – Potentially Occurring Special-Status Biological Resources
Scientific Name Status Habitat Potential to Occur
Southern Sycamore Alder Riparian
Woodland
CDFW Sensitive
Habitat
often occur along seasonally-flooded banks; cottonwoods and
willows are also often present. Poison oak, mugwort, elderberry No
Absent
This plant community was not
observed within or adjacent to the
U.S. Fish and Wildlife Service
(USFWS) - Federal
END- Federal Endangered
THR- Federal Threatened
California Department of Fish and
Wildlife (CDFW) - California
END- California Endangered
THR- California Threatened
CE - Candidate Endangered
FP- California Fully Protected
SSC- California Species of Concern
WL- Watch List
California Native Plant Society (CNPS)
California Rare Plant Rank
1A Plants Presumed Extirpated in California
and Either Rare or Extinct Elsewhere
1B Plants Rare, Threatened, or Endangered in
California and Elsewhere
2B Plants Rare, Threatened, or Endangered in
California, but More Common Elsewhere
4 Plants of Limited Distribution – A Watch
List
Threat Ranks
0.1- Seriously threatened in California
0.2- Moderately threatened in California
0.3- Not very threatened in California
Attachment E
Regulations
Attachment E – Regulations
Special status species are native species that have been afforded special legal or management protection
because of concern for their continued existence. There are several categories of protection at both federal
and state levels, depending on the magnitude of threat to continued existence and existing knowledge of
population levels.
Federal Regulations
Endangered Species Act of 1973
Federally listed threatened and endangered species and their habitats are protected under provisions of the
Federal Endangered Species Act (ESA). Section 9 of the ESA prohibits “take” of threatened or endangered
species. “Take” under the ESA is defined as to “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture,
or collect, or to attempt to engage in any of the specifically enumerated conduct.” The presence of any
federally threatened or endangered species that are in a project area generally imposes severe constraints
on development, particularly if development would result in “take” of the species or its habitat. Under the
regulations of the ESA, the United States Fish and Wildlife Service (USFWS) may authorize “take” when
it is incidental to, but not the purpose of, an otherwise lawful act.
Critical Habitat is designated for the survival and recovery of species listed as threatened or endangered
under the ESA. Critical Habitat includes those areas occupied by the species, in which are found physical
and biological features that are essential to the conservation of an ESA listed species and which may require
special management considerations or protection. Critical Habitat may also include unoccupied habitat if it
is determined that the unoccupied habitat is essential for the conservation of the species.
Whenever federal agencies authorize, fund, or carry out actions that may adversely modify or destroy
Critical Habitat, they must consult with USFWS under Section 7 of the ESA. The designation of Critical
Habitat does not affect private landowners, unless a project they are proposing uses federal funds, or
requires federal authorization or permits (e.g., funding from the Federal Highway Administration or a
permit from the U.S. Army Corps of Engineers (Corps)).
If USFWS determines that Critical Habitat will be adversely modified or destroyed from a proposed action,
the USFWS will develop reasonable and prudent alternatives in cooperation with the federal institution to
ensure the purpose of the proposed action can be achieved without loss of Critical Habitat. If the action is
not likely to adversely modify or destroy Critical Habitat, USFWS will include a statement in its biological
opinion concerning any incidental take that may be authorized and specify terms and conditions to ensure
the agency is in compliance with the opinion.
Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) (16 U.S. Government Code [USC] 703) makes it unlawful to
pursue, capture, kill, possess, or attempt to do the same to any migratory bird or part, nest, or egg of any
such bird listed in wildlife protection treaties between the United States, Great Britain, Mexico, Japan, and
the countries of the former Soviet Union, and authorizes the U.S. Secretary of the Interior to protect and
regulate the taking of migratory birds. It establishes seasons and bag limits for hunted species and protects
migratory birds, their occupied nests, and their eggs (16 USC 703; 50 CFR 10, 21).
Attachment E – Regulations
The MBTA covers the taking of any nests or eggs of migratory birds, except as allowed by permit pursuant
to 50 CFR, Part 21. Disturbances causing nest abandonment and/or loss of reproductive effort (i.e., killing
or abandonment of eggs or young) may also be considered “take.” This regulation seeks to protect migratory
birds and active nests.
In 1972, the MBTA was amended to include protection for migratory birds of prey (e.g., raptors). Six
families of raptors occurring in North America were included in the amendment: Accipitridae (kites, hawks,
and eagles); Cathartidae (New World vultures); Falconidae (falcons and caracaras); Pandionidae (ospreys);
Strigidae (typical owls); and Tytonidae (barn owls). The provisions of the 1972 amendment to the MBTA
protects all species and subspecies of the families listed above. The MBTA protects over 800 species
including geese, ducks, shorebirds, raptors, songbirds and many relatively common species.
State Regulations
California Environmental Quality Act (CEQA)
The California Environmental Quality Act (CEQA) provides for the protection of the environment within
the State of California by establishing State policy to prevent significant, avoidable damage to the
environment through the use of alternatives or mitigation measures for projects. It applies to actions directly
undertaken, financed, or permitted by State lead agencies. If a project is determined to be subject to CEQA,
the lead agency will be required to conduct an Initial Study (IS); if the IS determines that the project may
have significant impacts on the environment, the lead agency will subsequently be required to write an
Environmental Impact Report (EIR). A finding of non-significant effects will require either a Negative
Declaration or a Mitigated Negative Declaration instead of an EIR. Section 15380 of the CEQA Guidelines
independently defines “endangered” and “rare” species separately from the definitions of the California
Endangered Species Act (CESA). Under CEQA, “endangered” species of plants or animals are defined as
those whose survival and reproduction in the wild are in immediate jeopardy, while “rare” species are
defined as those who are in such low numbers that they could become endangered if their environment
worsens.
California Endangered Species Act (CESA)
In addition to federal laws, the state of California implements the CESA which is enforced by CDFW. The
CESA program maintains a separate listing of species beyond the FESA, although the provisions of each
act are similar.
State-listed threatened and endangered species are protected under provisions of the CESA. Activities that
may result in “take” of individuals (defined in CESA as; “hunt, pursue, catch, capture, or kill, or attempt to
hunt, pursue, catch, capture, or kill”) are regulated by CDFW. Habitat degradation or modification is not
included in the definition of “take” under CESA. Nonetheless, CDFW has interpreted “take” to include the
destruction of nesting, denning, or foraging habitat necessary to maintain a viable breeding population of
protected species.
The State of California considers an endangered species as one whose prospects of survival and
reproduction are in immediate jeopardy. A threatened species is considered as one present in such small
numbers throughout its range that it is likely to become an endangered species in the near future in the
Attachment E – Regulations
absence of special protection or management. A rare species is one that is considered present in such small
numbers throughout its range that it may become endangered if its present environment worsens. State
threatened and endangered species are fully protected against take, as defined above.
The CDFW has also produced a species of special concern list to serve as a species watch list. Species on
this list are either of limited distribution or their habitats have been reduced substantially, such that a threat
to their populations may be imminent. Species of special concern may receive special attention during
environmental review, but they do not have formal statutory protection. At the federal level, USFWS also
uses the label species of concern, as an informal term that refers to species which might be in need of
concentrated conservation actions. As the Species of Concern designated by USFWS do not receive formal
legal protection, the use of the term does not necessarily ensure that the species will be proposed for listing
as a threatened or endangered species.
Fish and Game Code
Fish and Game Code Sections 3503, 3503.5, 3511, and 3513 are applicable to natural resource management.
For example, Section 3503 of the Code makes it unlawful to destroy any birds’ nest or any birds’ eggs that
are protected under the MBTA. Further, any birds in the orders Falconiformes or Strigiformes (Birds of
Prey, such as hawks, eagles, and owls) are protected under Section 3503.5 of the Fish and Game Code
which makes it unlawful to take, possess, or destroy their nest or eggs. A consultation with CDFW may be
required prior to the removal of any bird of prey nest that may occur on a project site. Section 3511 of the
Fish and Game Code lists fully protected bird species, where the CDFW is unable to authorize the issuance
of permits or licenses to take these species. Pertinent species that are State fully protected by the State
include golden eagle (Aquila chrysaetos) and white-tailed kite (Elanus leucurus). Section 3513 of the Fish
and Game Code makes it unlawful to take or possess any migratory nongame bird as designated in the
MBTA or any part of such migratory nongame bird except as provided by rules and regulations adopted by
the Secretary of the Interior under provisions of the MBTA.
Native Plant Protection Act
Sections 1900–1913 of the Fish and Game Code were developed to preserve, protect, and enhance Rare
and Endangered plants in the state of California. The act requires all state agencies to use their authority to
carry out programs to conserve Endangered and Rare native plants. Provisions of the Native Plant
Protection Act prohibit the taking of listed plants from the wild and require notification of the CDFW at
least ten days in advance of any change in land use which would adversely impact listed plants. This allows
the CDFW to salvage listed plant species that would otherwise be destroyed.
California Native Plant Society Rare and Endangered Plant Species
Vascular plants listed as rare or endangered by the CNPS, but which have no designated status under FESA
or CESA are defined as follows:
California Rare Plant Rank
1A- Plants Presumed Extirpated in California and either Rare or Extinct Elsewhere
1B- Plants Rare, Threatened, or Endangered in California and Elsewhere
Attachment E – Regulations
2A- Plants Presumed Extirpated in California, But More Common Elsewhere
2B- Plants Rare, Threatened, or Endangered in California, But More Common Elsewhere
3- Plants about Which More Information is Needed - A Review List
4- Plants of Limited Distribution - A Watch List
Threat Ranks
.1- Seriously threatened in California (over 80% of occurrences threatened / high degree and
immediacy of threat)
.2- Moderately threatened in California (20-80% occurrences threatened / moderate degree and
immediacy of threat)
.3- Not very threatened in California (<20% of occurrences threatened / low degree and immediacy
of threat or no current threats known).
Attachment E – Regulations
There are three key agencies that regulate activities within inland streams, wetlands, and riparian areas in
California. The Corps Regulatory Branch regulates activities pursuant to Section 404 of the Federal Clean
Water Act (CWA) and Section 10 of the Rivers and Harbors Act. Of the State agencies, the CDFG regulates
activities under the Fish and Game Code Section 1600-1616, and the Regional Board regulates activities
pursuant to Section 401 of the CWA and the California Porter-Cologne Water Quality Control Act.
Federal Regulations
Section 404 of the Clean Water Act
In accordance with the Revised Definition of “Waters of the United States”; Conforming (September 8,
2023), “waters of the United Sates” are defined as follows:
(a) Waters of the United States means:
(1) Waters which are:
(i) Currently used, or were used in the past, or may be susceptible to use in interstate or foreign
commerce, including all waters which are subject to the ebb and flow of the tide;
(ii) The territorial seas; or
(iii) Interstate waters;
(2) Impoundments of waters otherwise defined as waters of the United States under this definition,
other than impoundments of waters identified under paragraph (a)(5) of this section;
(3) Tributaries of waters identified in paragraph (a)(1) or (2) of this section that are relatively
permanent, standing or continuously flowing bodies of water;
(4) Wetlands adjacent to the following waters:
(i) Waters identified in paragraph (a)(1) of this section; or
(ii) Relatively permanent, standing or continuously flowing bodies of water identified in paragraph
(a)(2) or (a)(3) of this section and with a continuous surface connection to those waters;
(5) Intrastate lakes and ponds not identified in paragraphs (a)(1) through (4) of this section that are
relatively permanent, standing or continuously flowing bodies of water with a continuous surface
connection to the waters identified in paragraph (a)(1) or (a)(3) of this section
(b) The following are not “waters of the United States” even where they otherwise meet the terms of
paragraphs (a)(2) through (5) of this section:
(1) Waste treatment systems, including treatment ponds or lagoons, designed to meet the
requirements of the Clean Water Act;
(2) Prior converted cropland designated by the Secretary of Agriculture. The exclusion would cease
upon a change of use, which means that the area is no longer available for the production of
agricultural commodities. Notwithstanding the determination of an area's status as prior converted
Attachment E – Regulations
cropland by any other Federal agency, for the purposes of the Clean Water Act, the final authority
regarding Clean Water Act jurisdiction remains with EPA;
(3) Ditches (including roadside ditches) excavated wholly in and draining only dry land and that do
not carry a relatively permanent flow of water;
(4) Artificially irrigated areas that would revert to dry land if the irrigation ceased;
(5) Artificial lakes or ponds created by excavating or diking dry land to collect and retain water and
which are used exclusively for such purposes as stock watering, irrigation, settling basins, or rice
growing;
(6) Artificial reflecting or swimming pools or other small ornamental bodies of water created by
excavating or diking dry land to retain water for primarily aesthetic reasons;
(7) Waterfilled depressions created in dry land incidental to construction activity and pits excavated
in dry land for the purpose of obtaining fill, sand, or gravel unless and until the construction or
excavation operation is abandoned and the resulting body of water meets the definition of waters of
the United States; and
(8) Swales and erosional features (e.g., gullies, small washes) characterized by low volume,
infrequent, or short duration flow.
(c) In this section, the following definitions apply:
(1) Wetlands means those areas that are inundated or saturated by surface or ground water at a
frequency and duration sufficient to support, and that under normal circumstances do support, a
prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally
include swamps, marshes, bogs, and similar areas.
(2) Adjacent means having a continuous surface connection
(3) High tide line means the line of intersection of the land with the water's surface at the maximum
height reached by a rising tide. The high tide line may be determined, in the absence of actual data, by
a line of oil or scum along shore objects, a more or less continuous deposit of fine shell or debris on
the foreshore or berm, other physical markings or characteristics, vegetation lines, tidal gages, or
other suitable means that delineate the general height reached by a rising tide. The line encompasses
spring high tides and other high tides that occur with periodic frequency but does not include storm
surges in which there is a departure from the normal or predicted reach of the tide due to the piling up
of water against a coast by strong winds such as those accompanying a hurricane or other intense
storm.
(4) Ordinary high water mark means that line on the shore established by the fluctuations of water
and indicated by physical characteristics such as clear, natural line impressed on the bank, shelving,
changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris,
or other appropriate means that consider the characteristics of the surrounding areas.
Attachment E – Regulations
(5) Tidal waters means those waters that rise and fall in a predictable and measurable rhythm or cycle
due to the gravitational pulls of the moon and sun. Tidal waters end where the rise and fall of the
water surface can no longer be practically measured in a predictable rhythm due to masking by
hydrologic, wind, or other effects.
Section 401 of the Clean Water Act
Pursuant to Section 401 of the CWA, any applicant for a federal license or permit to conduct any activity
which may result in any discharge to waters of the United States must provide certification from the State
or Indian tribe in which the discharge originates. This certification provides for the protection of the
physical, chemical, and biological integrity of waters, addresses impacts to water quality that may result
from issuance of federal permits, and helps insure that federal actions will not violate water quality
standards of the State or Indian tribe. In California, there are nine Regional Water Quality Control Boards
(Regional Board) that issue or deny certification for discharges to waters of the United States and waters of
the State, including wetlands, within their geographical jurisdiction. The State Water Resources Control
Board assumed this responsibility when a project has the potential to result in the discharge to waters within
multiple Regional Boards.
State Regulations
Fish and Game Code
Fish and Game Code Sections 1600 et. seq. establishes a fee-based process to ensure that projects conducted
in and around lakes, rivers, or streams do not adversely impact fish and wildlife resources, or, when adverse
impacts cannot be avoided, ensures that adequate mitigation and/or compensation is provided.
Fish and Game Code Section 1602 requires any person, state, or local governmental agency or public utility
to notify the CDFW before beginning any activity that will do one or more of the following:
(1) substantially obstruct or divert the natural flow of a river, stream, or lake;
(2) substantially change or use any material from the bed, channel, or bank of a river, stream, or lake;
or
(3) deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground
pavement where it can pass into a river, stream, or lake.
Fish and Game Code Section 1602 applies to all perennial, intermittent, and ephemeral rivers, streams, and
lakes in the State. CDFW’s regulatory authority extends to include riparian habitat (including wetlands)
supported by a river, stream, or lake regardless of the presence or absence of hydric soils and saturated soil
conditions. Generally, the CDFW takes jurisdiction to the top of bank of the stream or to the outer limit of
the adjacent riparian vegetation (outer drip line), whichever is greater. Notification is generally required
for any project that will take place in or in the vicinity of a river, stream, lake, or their tributaries. This
includes rivers or streams that flow at least periodically or permanently through a bed or channel with banks
that support fish or other aquatic life and watercourses having a surface or subsurface flow that support or
have supported riparian vegetation. A Section 1602 Streambed Alteration Agreement would be required if
impacts to identified CDFW jurisdictional areas occur.
Attachment E – Regulations
Porter Cologne Act
The California Porter-Cologne Water Quality Control Act gives the State very broad authority to regulate
waters of the State, which are defined as any surface water or groundwater, including saline waters. The
Porter-Cologne Act has become an important tool in the post SWANCC and Rapanos regulatory
environment, with respect to the state’s authority over isolated and insignificant waters. Generally, any
person proposing to discharge waste into a water body that could affect its water quality must file a Report
of Waste Discharge in the event that there is no Section 404/401 nexus. Although “waste” is partially
defined as any waste substance associated with human habitation, the Regional Board also interprets this
to include fill discharged into water bodies.