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

BIO-6.2: Delta smelt and Sacramento splittail. For work in infested North Bay marshes where delta smelt or Sacramento splittail may occur (currently one: Southhampton Marsh, Benicia), eliminate impoundment techniques and minimize spray drift near tidal creeks (MITIGATION BIO-1.1, 1.2). Restrict any intertidal excavation or dredging in tidal creeks to tidal stages when target areas are emerged above water level.

Not Applicable

Applicable

Not Applicable

Applicable

Not Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment

BIO-6.4: Shallow-water estuarine fish. Dredging of infested intertidal channels should be limited to tidal stages when target areas are emerged above water level. Water intakes for impoundments should have invert elevations 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 near channels. 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

BIO-8: Mosquito production in tidal marshes. Monitor access routes in marshes to detect formation of undrained depressions in tire ruts or foot trails. Backfill access-related shallow marsh depressions or incise narrow drainages so they do not impound small, sheltered areas of standing water. Where impoundments are used, design impoundments of sufficient size and depth to minimize mosquito breeding habitat.

Applicable

Applicable

Applicable

Applicable

Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment


 

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

Air Quality

Mitigation AQ-1: Dust emissions. Apply dust control measures where treatment methods may produce visible dust clouds and where sensitive receptors (i.e., houses, schools, hospitals) are located within 500 feet of the treatment site. The following dust control measures should be included in the site-specific work plans:

*       Suspend activities when winds are too great to prevent visible dust clouds from affecting sensitive receptors.

*       Limit traffic speeds on any dirt access roads to 15 miles per hour.

Not Applicable

Applicable

Applicable

Applicable

Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment

Mitigation AQ-2: Smoke and ash emissions. For prescribed burns, notify the Bay Area Air Quality Management District and the Agriculture Commissioner prior to initiating the burn, and/or obtain a burn permit.

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Applicable

Not Applicable

Treating contractor, agency, or organization

ISP field supervisor

Prior to treatment

Mitigation AQ-3: Herbicide effects on air quality. For areas targeted for aerial application of herbicides that are within 0.5 mile of sensitive receptors (i.e., houses, schools, hospitals), prepare and implement an herbicide drift management plan to reduce the possibility of chemical drift into populated areas. Avoid spraying when winds exceed 10 miles per hour, consistent with California supplemental labeling The plan shall include the following elements: coordination, sensitive receptors, equipment use, meteorological conditions, buffer zones, restriction on public access, and alternative spray method.

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

Prior to treatment


 

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

 

Noise

 

Mitigation N-1: Disturbance of sensitive receptors.

N-1A. The use of equipment and machinery shall comply with all applicable local noise ordinances and policies. At a minimum, the use of equipment and machinery in cordgrass removal shall be limited to weekdays (Monday-Friday) between the hours of 7:00 a.m. to 7:00 p.m. within 500 feet of sensitive receptors.

N-1B. Helicopters shall not be used within 1,500 feet of sensitive receptors.

Not Applicable

Applicable

Applicable

Applicable

Not Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment

 

Human Health and Safety

 

Mitigation HS-1: Worker injury from accidents associated with non-native cordgrasstreatment. Appropriate safety procedures and equipment shall be used by treatment workers. All workers shall be provided adequate training to ensure worker safety.

Applicable

Applicable

Applicable

Applicable

Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment

Mitigation HS-2: Worker health effects from herbicide application. Appropriate health and safety procedures and equipment, as described on the herbicide or surfactant label, including personal protective equipment, shall be used by workers to minimize risks associated with chemical treatment methods. Only certified or licensed herbicide applicators shall mix and apply herbicide.

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment

Mitigation HS-3: Herbicide application shall be managed to minimize potential for herbicide drift, particularly in areas where the public could be affected. Herbicide shall not be applied when winds are in excess of 10 miles per hour or when inversion conditions exist (per Supplemental Labeling for Aquamaster for Aerial Application in California Only), or when wind could carry spray drift into inhabited areas.

Colored signs shall be posted at and/or near any public trails, boat launches, or other potential points of access to herbicide application sites a minimum of 24 hours prior to treatment. They will advise "no entry" for humans and animals until a minimum of eight (8) hours after treatment, and that date and time will be stated. A 24-hour ISP contact number shall be provided.

Application of herbicides shall be avoided near areas where the public is likely to contact water or vegetation as follows:

A. Large-scale application of herbicides in or adjacent to high use areas shall not be allowed within 24 hours prior to weekends and public holidays.

B. If a situation arises (due to weather or other variables) that makes it necessary to treat high-use areas on weekends or holidays, the areas shall be closed to the public for 24 hours before and after treatment.

At least one week prior to application, signs informing the public of impending herbicide treatment shall be posted at prominent locations within a 500-foot radius of treatment sites where homes, schools, hospitals, or businesses could be affected. Schools and hospitals within 500 feet of any treatment site shall be separately noticed at least one week prior to the application. No aerial spraying shall be conducted within 0.25 mile of a school, hospital, or other sensitive receptor.

 

N

Not Applicable

 

Not Applicable

 

Not Applicable

 

Not Applicable

 

Not Applicable

 

Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment

Mitigation HS-4: Health effects to workers or the public from accidents associated with non-native cordgrass treatment. Appropriate health and safety procedures and equipment shall be used to minimize risks to the public from exposure to fuel spills or other petroleum products, and herbicides.

Not Applicable

Applicable

Applicable

Applicable

Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment

Visual Resources

 

MitigationVIS-1: The ISP will integrate signage into all treatment areas that are adjacent or within areas accessible or visible to the general public, whenever the treatment of nonnative Spartina will result in a substantial change in the visual character of the area. Signage will vary depending upon the site-specific components of treatment methods, availability and nature of public access and visibility, extent of the infestation, and other factors. Signage will therefore range from simple signs providing a brief description of the nature and reason for the change (e.g. where there is little public visibility or the extent of infestation is small) to more detailed interpretive signs highlighting the ecological effects of Spartina and the need for control (e.g. where there is significant public access and high visibility, and infestation is broad).

 

Applicable

Applicable

Applicable

Applicable

Applicable

Applicable

Treating contractor, agency, or organization

ISP field supervisor

Prior to treatment

Cultural Resources

 

Mitigation CUL-1: Disturbance or destruction of cultural resources from access and treatment. a. For all sites proposed for ground-disturbing control methods and ground-disturbing access (other than manual removal and smothering) a qualified archaeologist shall conduct a Phase I prehistoric and historical resource site record and literature search to assess the site's cultural resource sensitivity and the potential for project-related impacts.

The literature search shall include a review of historic maps to determine whether the site is located on construction fill and whether historic buildings or structures are or were located within its boundaries.

The record search shall identify all recorded prehistoric and historic sites in the site and identify previous cultural resource studies conducted in or adjacent to the site.

The Phase 1 report shall assess potential impacts and, if needed, recommend site-specific measures to avoid or reduce potential impacts to less than significant levels.

If treatment requires excavations at any prehistoric or historic cultural resource sites, then excavations will be monitored by local Native American representatives identified by the Native American Heritage Commission.

If the Phase 1 report finds that there are significant cultural resources, then an alternative treatment method that does not disturb the cultural resources (i.e. herbicide treatment) must be used. Otherwise, if the resource is determined significant and impacts cannot be avoided, then the lead Federal agency shall consult with the California Office of Historic Preservation (OHP) to identify appropriate mitigation measures (e.g. data recovery recordation) to reduce impacts to less than significant levels

Applicable

Applicable

Applicable

Applicable

Not Applicable

Not Applicable

Treating contractor, agency, or organization

ISP field supervisor

Prior to treatment

 

b. For sites involving manual removal or smothering of invasive cordgrass and not requiring ground-disturbing access, if prehistoric or historic cultural resources are discovered during digging, the project sponsor will suspend all work in the immediate vicinity of the find pending site investigation by a qualified archaeologist or historic resources consultant to assess the materials and determine their significance. If the qualified archaeologist/ historic resource consultant determines that the find is an important resource, the project sponsor will provide funding and time to allow recovering an archaeological sample or to implement avoidance measures. Work could continue at other locations while archaeological mitigation takes place.

Applicable

Applicable

Applicable

Applicable

Not Applicable

Not Applicable

Treating contractor, agency, or organization

ISP field supervisor

During treatment

 

Mitigation CUL-2: Loss of cultural resources from erosion. Project implementation and erosion control measures shall be designed to avoid damaging potentially significant cultural resource sites, as specified in Mitigation CUL-1, above.

Not Applicable

Applicable

Not Applicable

Applicable

Applicable

Not Applicable

Treating contractor, agency, or organization

ISP Field supervisor

Prior to and during treatment