APPENDIX K

Final Programmatic Environmental Impact Statement/Environmental Impact Report
San Francisco Estuary Invasive Spartina Project: Spartina Control Program
September 2003

APPENDIX K: MITIGATION MONITORING AND REPORTING PROGRAM:
INVASIVE SPARTINA PROJECT, SPARTINA CONTROL PROGRAM SEPTEMBER 2003

ATTACHMENT 2:

Mitigation Monitoring and Reporting Program

for the San Francisco Estuary Invasive Spartina Project Programmatic EIS/R

Mitigation	Manual Removal (Hand pulling and manual excavation)	Mechanical Removal (Excavation, dredging, and shredding)	Pruning, Hand-mowing, and Smothering	Flooding (Diking, drowning, and salinity variation)	Burning	Herbicide Application	Implementing Responsibility	Monitoring Responsibility	Mitigation Timing
Hydrology and Geomorphology
Mitigation GEO-1: Erosion or deposition of sediment. In sites of cordgrass removal where unacceptable increases in erosion rates (significantly greater than background levels or threatening the stability of existing infrastructure such as access roads or utility structures) are likely, temporary physical erosion controls shall be established until sediments either consolidate or stabilize naturally.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP Field Supervisor	Prior to start of removal operations
Mitigation GEO-2: Erosion or topographic change by vehicles used in eradication. Vehicle travel in the tidal marsh and mudflat shall be minimized. Mats shall be used to distribute the weight of vehicles on marsh surfaces wherever feasible. Sensitive sites that could be significantly impacted by erosion or sedimentation from overland vehicles shall be accessed by boat.	Not Applicable	Applicable	Not applicable	Not Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP Field Supervisor	During removal operations
Mitigation GEO-3: Remobilization of sand. Resumed erosion at sensitive locations shall be mitigated by sand nourishment or repair or replacement of existing rock slope protection or existing erosion control structure.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP Field Supervisor	During removal operations
Mitigation GEO-4: Sediment disposal. Sediments dredged from treatment sites shall be disposed of as prioritized in the Long Term Management Strategy for Bay dredged material. These sediments shall not be disposed of in dredge disposal sites in the Estuary or offshore where seeds may be dispersed elsewhere in the Estuary or to other coastal estuaries. They shall be disposed of in upland disposal sites or at depths in sites proposed for tidal marsh restoration.	Not Applicable	Applicable	Not Applicable	Not Applicable	Not Applicable	Not Applicable	Treating contractor, agency, or organization	ISP Field Supervisor	During removal operations

ISP Field Supervisor – Field Operations Manager, Field Biologist, or designee assigned to specific project site.

Mitigation	Manual Removal (Hand pulling and manual excavation)	Mechanical Removal (Excavation, dredging, and shredding)	Pruning, Hand-mowing, and Smothering	Flooding (Diking, drowning, and salinity variation)	Burning	Herbicide Application	Implementing Responsibility	Monitoring Responsibility	Mitigation Timing
Water Quality
Mitigation WQ-1: Degradation due to herbicide application. Herbicides shall be applied under NPDES Permit from the State. Herbicides shall be applied directly to plants and at low tide to minimize the potential application of herbicide directly on the water surface, and shall be applied in accordance with application guidelines and the manufacturer label. Best management practices shall be applied at all times. The ISP Control Program shall monitor and evaluate projects.	Not Applicable	Not Applicable	Not Applicable	Not Applicable	Not Applicable	Applicable	Herbicide applicat-ors	ISP field supervisor	During treatment operations
Mitigation WQ-2: Herbicide spills. Herbicides shall be applied under NPDES Permit from the State, and by or under the direct supervision of a trained, certified or licensed applicator. Spill prevention and containment plan shall be developed and implemented.	Not Applicable	Not Applicable	Not Applicable	Not Applicable	Not Applicable	Applicable	Herbicide applicat-ors Treating contractor, agency, or organization	ISP field supervisor ISP field supervisor	During treatment operations Prior to treatment operations
Mitigation WQ-3: Fuel or petroleum spills. Fueling and storage of fuels will be maintained offsite. A spill prevention and containment plan shall be developed and implemented.	Not Applicable	Applicable	Not Applicable	Applicable	Applicable	Applicable	Treatment crews/contractors Treating contractor, agency, or organization	ISP field supervisor ISP field supervisor	During treatment operations Prior to treatment operations
Mitigation WQ-4: Contaminant remobilization. Site sediments will be researched and sampled (if needed) prior to initiating treatment of any site where there may be contamination. Waste Discharge Requirements shall be obtained for operations in a site where contamination is present.	Applicable	Applicable	Not Applicable	Usually Not Applicable	Not Applicable	Not Applicable	Treeating agency or organization	ISP field supervisor	Prior to treatment operations

Mitigation	Manual Removal (Hand pulling and manual excavation)	Mechanical Removal (Excavation, dredging, and shredding)	Pruning, Hand-mowing, and Smothering	Flooding (Diking, drowning, and salinity variation)	Burning	Herbicide Application	Implementing Responsibility	Monitoring Responsibility	Mitigation Timing
Biological Resources
BIO-1.1. Bio 1.2, and Bio-1.3: Tidal marsh plant communities. Minimize vehicle and foot access pathways. Restrict equipment working in marsh plains to mats and geotextile fabric covers. Stockpile non-viable excavated non-native cordgrass and excavated sediment and remove from marsh. Cover non-target vegetation with fabric adjacent to areas sprayed with herbicide, or pre-treat with protective films of silt-clay. Stabilize smothering geotextile mats. Use optimal combinations of treatment to minimize repeat entry to marsh and re-treatment. Minimize herbicide spray dose requirements by pre-treatments. Use removal methods rather than helicopter applications of herbicide whenever feasible and less environmentally damaging. Use non-spray application techniques to reduce herbicide dose and minimize non-target contact.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-1.4: Submerged aquatic plant communities. Remove large deposits of mown cordgrass during the growing season; or install temporary water-permeable debris barriers around vulnerable pans. Avoid transporting tanks of spray solution near pans.	Not Applicable	Not Applicable	Applicable	Not Applicable	Not Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-2: Special-status plant species. Conduct pre-project spring surveys for sensitive plants and instruct field crews to avoid and protect sensitive populations. Require qualified, experienced on-site botanical supervision if sensitive plants occur in the vicinity. If sensitive plant populations occur near the high tide line, rake and remove large deposits of mown cordgrass during the growing season. Refrain from burning in marshes supporting sensitive plant species. Stabilize smothering geotextile mats. Cover non-target vegetation, or install spray-drift barriers. If accidental exposure to spray drift occurs, thoroughly irrigate affected plants with silt-clay suspensions. Refrain from rapid replanting of Pacific cordgrass until Atlantic smooth cordgrass pollen and seed rain is minimal.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-3: Shorebirds and waterfowl. For work within 1,000 feet of mudflats, schedule eradication activities to avoid peak fall and spring Pacific Flyway stopovers. Mobilize crews to project sites before mudflats emerge. Use optimal combinations of treatment to minimize repeat entry. Avoid helicopter applications of herbicide to mudflat colonies within 1,000 feet of major habitual roosting or foraging sites. As a last resort, haze shorebirds and waterfowl within 1,000 feet of spray operations. Remediate small volumes of spilled solutions on mudflats.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-4.1: Salt marsh harvest mouse and tidal marsh shrew subspecies. Minimize vehicle and foot access pathways in potential tidal marsh habitat. Restrict equipment working in marsh to areas with mats and geotextile fabric covers. Use optimal combinations of treatment to minimize repeat entry re-treatment. Schedule work in suitable habitat soon after natural mass-mortality events caused by extreme high tides. Compensatory measures for incidental take include restoration of optimal habitat within large tidal marsh restoration projects.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-4.2: Resident San Francisco Bay harbor seals. Minimize vehicle and foot access pathways in marsh within 1,000 feet of seal haul-outs, and avoid approaching haul-outs within 2,000 feet, or any distance that elicits vigilance behavior when pups are present. Consult with marine mammal experts to determine seasonal variation in sensitivity to disturbance. Restrict equipment working in marsh to prescribed paths. Use optimal combinations of treatment to minimize repeat entry to marsh and re-treatment. Refrain from use of low-flying helicopters within 2,000 feet of seal haul-outs. Transport any pre-mixed solutions of herbicide in double-lined containers. Remediate spilled solutions on mudflats to the greatest extent feasible.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-5.1: California clapper rail. To minimize or avoid indirect impacts of eradication operations on clapper rails, follow "best management practices" in EIS/R Appendix G, as modified by the US Fish and Wildlife Service's Biological Opinion. These protocols are based on (1) current survey and map data to determine distribution and abundance of rails in relation to project sites, and local behavior of rails in occupied habitats; (2) training and expert biological supervision of field crews to detect clapper rails and identify habitat; (3) modification of timing and within-site location of operations to minimize or avoid disturbances to clapper rails. In addition, the mitigation measures generally used to minimize disturbances in MITIGATION BIO-1.2 and BIO-4.1 also apply. For unavoidable significant impacts due to eradication of Atlantic smooth cordgrass and hybrids which provide habitat currently occupied by clapper rails, proportional compensatory mitigation is necessary. Primary components of compensatory mitigation include: (1) large-scale, rapid restoration of suitable tidal salt marsh habitat (including all essential habitat components for colonization by clapper rails) in advance of large-scale habitat destruction, and within the same subregion as impacts, but at locations with low invasion pressure from non-native cordgrasses; (2) significantly increasing reproductive success of clapper rails within the same subregion as impacts, through management which reduces predation from non-native red fox, and enhances flood refugia (cover for rails during extreme high tides).	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-5.2: California black rail. Adapt protocols for minimization and avoidance of California clapper rails (Appendix G) for work in infested marshes known to support populations of California black rails (currently one: Southhampton Marsh, Benicia), emphasizing pre-project surveys (call detection), minimization of marsh disturbance (MITIGATION BIO-1.2), and avoidance of occupied habitat during the breeding season.	Applicable	Potentially Applicable	Applicable	Not Applicable	Not Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-5.3: Tidal marsh song sparrow subspecies and salt marsh common yellowthroats. Adapt protocols for minimization and avoidance of California clapper rails (EIS/R, Appendix G) for work in infested marshes known to support populations of Alameda song sparrows, San Pablo song sparrows, Suisun song sparrow, and the salt marsh common yellowthroat, emphasizing pre-project surveys, minimization of marsh disturbance (MITIGATION BIO-1.2), and avoidance of occupied habitat during the breeding season.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-5.4: Western snowy plovers and California least terns. Prior to levee access in areas where snowy plovers and least terns may breed, levee routes should be surveyed for potential nests, including nests in salt pond beds near levee roads. Dredging and excavation of cordgrass should be conducted either after least terns have migrated out of San Francisco Bay, or during middle to lower tidal stages that allow navigation of barge and crane operations, while exposing the maximum extent of cordgrass above standing tides.	Applicable	Applicable	Applicable	Applicable	Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-5.5: Birds of prey in tidal marshes. Minimize use of helicopters to apply herbicides over marshplains where raptors forage.	Not Applicable	Not Applicable	Not Applicable	Not Applicable	Not Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment
BIO-6.1: Chinook salmon and steelhead (anadromous salmonids). Dredging of infested intertidal channels should be limited to: (1) tidal stages when target areas are emerged above water level, and (2) during seasons when winter- and spring-run Chinook salmon and steelhead migration times minimize their risk of exposure at project sites, particularly juveniles. Intakes for impoundments should be limited to tides above mean high water to minimize entrainment and trapping. Alternatively, fish screens could be installed on new tidegates used to impound and drown large cordgrass-infested marshes in former diked baylands. Herbicide methods should be minimized or avoided near channels and mudflats during migration periods of winter-run and spring-run Chinook salmon and steelhead. Minimize glyphosate/surfactant spray application requirements by pre-treating target cordgrass stands with mechanical methods that reduce cordgrass biomass and density, increase receptivity and coverage of spray, and increase mortality response to glyphosate. In case of herbicide/surfactant solution spill, remediate small volumes of spilled solutions on mudflats to the greatest extent feasible by suction of surface muds, using portable wet vacuum or pumping equipment.	Not Applicable	Applicable	Not Applicable	Applicable	Not Applicable	Applicable	Treating contractor, agency, or organization	ISP field supervisor	During treatment