Attachment_C_PAGC_Existing_Conditions_Rpt_20240823_Reduced.pdf

983 University Avenue, Building D Los Gatos, CA 95032 408.458.3200 www.harveyecology.com

Palo Alto Municipal Golf Course Reconfiguration Project Wetland Mitigation Condition Assessment

Project #4821-01

Prepared for:

Lam Do City of Palo Alto

250 Hamilton Avenue Palo Alto, CA 94301

Prepared by:

H. T. Harvey & Associates

August 16, 2024 http://www.harveyecology.com/

Palo Alto Municipal Golf Course Reconfiguration Project Wetland Mitigation Condition Assessment i H. T. Harvey & Associates

Executive Summary

Permit Numbers

• U.S. Army Corps of Engineers (USACE) File No. 2013-00109S

• Regional Water Quality Control Board (RWQCB) Water Quality Certification Site No. 02-01-C0698 [bkw], California Integrated Water Quality System Place No. 802332

• U. S. Fish & Wildlife Service (USFWS) Informal Consultation on the Reconfiguration of the Palo Alto Municipal Golf Course in the City of Palo Alto, Santa Clara County, California.

Background The City of Palo Alto constructed the City of Palo Alto Municipal Golf Course Reconfiguration Project (project) in 2016 and 2017 at the Baylands Golf Links golf course located at 1875 Embarcadero Road in Palo Alto, California. Reconfiguration of the golf course required permanent and temporary impacts to wetlands/waters of the United States and State located at the project site (Table ES-1). Permits for the project were issued by RWQCB and USACE and USFWS was consulted on potential effects of the project to federally listed species. The project included 8.03 acres of wetland expansion and 0.42 of enhancement of existing wetlands at the golf course project site. Of this amount, the project’s permits require at least 4.0 acres of wetland expansion (i.e., wetland creation) and 0.20 acres of wetland enhancement to compensate for the project’s impacts (Table ES-2). The plan to expand and enhance the project wetlands is provided in the project’s Mitigation and Monitoring Plan (MMP) prepared by ICF International in 2016. Herein we use the term “wetland expansion” for consistency with the terminology in the MMP and permits; this term refers to the conversion of uplands to wetlands (i.e., wetland creation/establishment).

Table ES-1. Project Impacts on Waters of the United States by Activity Type

Project Impact Impact (acres)

Temporary impacts to non-tidal brackish marsh 0.29

Permanent impacts to non-tidal brackish marsh 1.36

Table ES-2. Compensatory Wetland Mitigation Quantities

Mitigation Type Required Amount to Compensate for Impacts (acres)

Proposed Wetland Expansion and Enhancement (acres)

Expansion (Creation/Establishment)

4.00 8.03

Enhancement 0.20 0.42

Total 4.20 8.45

Project Wetland Mitigation Condition Assessment ii H. T. Harvey & Associates

The City of Palo Alto implemented the grading, seeding, and planting to expand and enhance 8.45 acres of wetland habitat in 2016 and 2017, based on project construction submittals, change orders, completion dates provided by the City of Palo Alto and H. T. Harvey & Associates’ review of the construction contractor’s As- Built Drawings. H. T. Harvey & Associates provided a cursory review of the As-Built Drawings and observed that the drawings generally align with the plans in the project's MMP with some minor deviations presented in the body of this report.

The project’s permits and MMP call for a minimum of 5 years of habitat monitoring of the 8.45 acres of expanded and enhanced wetlands. Wetland mitigation monitoring was required from 2017 through 2021. This monitoring was not performed by the City of Palo Alto. In 2024, the City of Palo Alto retained H. T. Harvey & Associates to perform habitat monitoring required in the MMP. Through email communications with the City of Palo Alto, RWQCB has indicated that the purpose of the 2024 monitoring is to determine the existing condition of the mitigation wetlands and does not constitute annual monitoring. RWQCB has also indicated that the failure to monitor the mitigation wetlands and provide other required report submittals has triggered the need for additional mitigation wetlands, as specified in RWQCB permit Condition 33. Finally, RWQCB has requested a plan be developed to correct any deficiencies in the performance of the existing mitigation wetlands.

This report provides monitoring results relative to MMP performance criteria and makes conceptual recommendations for next steps to make progress toward meeting performance criteria where criteria were not met.

Methods Per the project’s MMP, the success of the project will be evaluated throughout the 8.45 acres of expanded and enhanced wetlands based on the following metrics:

• absolute cover of native hydrophytic plants,

• invasive plant cover,

• plant health and vigor,

• plant species richness,

• California Rapid Assessment Method (CRAM) assessment, and

• hydric soil monitoring

Additionally, the following observations are required:

• natural recruitment,

• hydrologic monitoring,

• salinity monitoring, Project Wetland Mitigation Condition Assessment iii H. T. Harvey & Associates

• photo documentation, and

• observational Paspalum TE (Paspalum vaginatum) (i.e., a patented variety of seashore paspalum used as the golf course turf grass) monitoring within the mitigation wetlands and 10-foot buffers.

H. T. Harvey assessed those metrics throughout the 8.45 acres of expanded and enhanced wetlands shown in the projects MMP (with the exceptions of a CRAM assessment which was not conducted following discussion with RWQCB) and compared the results to the Year 5 (i.e., final) performance criteria provided in Table ES-3.

The expanded and enhanced wetlands are required to be evaluated separately.

Table ES-3. Year 5 Performance Criteria

Monitoring Metric Year 5 Performance Criteria

Biologic Metrics

Absolute cover of native hydrophytic plants >70%

Absolute cover of invasive species <15%

Health and vigor >90% in good or fair condition

Species richness At least 5 native hydrophytic species

Physical Metrics

Hydric Soils Presence of hydric soils

CRAM Assessment CRAM score between 90 and 95

Additionally, we sought to determine how individual wetland areas composing the 8.45 acres compared to the performance criteria to inform our recommendations. To identify whether portions of the 8.45-acre mitigation wetland area met the project’s Year 5 performance criteria, we divided the expanded and enhanced wetland areas into spatially contiguous areas referred to herein as “wetland groups” and analyzed these wetlands groups separately and combined. Specifically, each wetland group is located within the same depressional area below the elevation of the surrounding golf course. Since the enhanced wetlands are required to be evaluated separately from the expanded wetlands and are relatively small, the enhanced wetlands were assessed as one wetland group.

Results None of the expanded wetland groups or the enhanced wetlands met all the native wetland absolute cover Year 5 performance criteria (Table ES-4). While none of the expanded wetland groups or the enhanced wetlands met the native wetland absolute cover Year 5 performance criteria, numerous nonnative, noninvasive (per MMP definition), hydrophytic plant species are present throughout the mitigation wetlands. When considering all noninvasive hydrophytic plant species, wetland plant cover exceeds 70% in expanded wetland groups 1, 2, and

4. The other wetland groups and the enhanced wetlands have 49% to 67% hydrophytic vegetation cover, indicating that the mitigation wetlands are mainly supporting hydrophytic vegetation.

Project Wetland Mitigation Condition Assessment iv H. T. Harvey & Associates

Table ES-4. Summary of Year 5 Performance Criteria Met by Wetland Group

Year 5 Performance Criteria

Wetland Group

Approximate Surface Area (Acre)1

Absolute Cover of Native Hydrophytic Plants

Absolute Cover of Invasive Species

Health and Vigor

Species Richness2

Hydric Soils

Year 5 Performance Criteria

>70% Native Hydrophytic Plant cover

<15% Invasive Plant Cover

>90% in Good or Fair Condition

At Least 5 Native Wetland Plant Species

Presence of Hydric Soils

Expanded Wetland Group 1

2.61 No Yes Yes NA3 Yes

Expanded Wetland Group 2

2.80 No No Yes NA Yes

Expanded Wetland Group 3

0.25 No No Yes NA Yes

Expanded Wetland Group 4

1.66 No Yes Yes NA Yes

Expanded Wetland Group 5

0.30 No No Yes NA Yes

Expanded Wetland Group 6

0.41 No Yes Yes NA No

All Expanded Wetland Groups

8.03 No No Yes Yes No

All Enhanced Wetlands

0.42 No No Yes No Yes

1 Wetland areas were calculated based on shapefiles created by ICF for the Palo Alto Golf Course Reconfiguration Project. Total expanded wetland and enhanced wetland areas are taken from the Project’s MMP. A post-construction wetland delineation was not conducted to verify these areas.

2 Species Richness was assessed at the landscape level per the mitigation and monitoring plan (ICF International 2016).

3 NA = Not Applicable, Species Richness is evaluated at the landscape scale (all expanded and all enhanced wetlands) per the mitigation and monitoring plan.

Only three of the expanded wetland groups met the absolute cover of invasive species Year 5 performance criteria. However, we note that the definition of invasive plants is broad in this project’s MMP; invasive species include all species rated as “moderate” or “high” by the California Invasive Plant Council. Therefore, some nonnative species that are commonly found in wetlands throughout California (and considered naturalized by the Jepson Manual) are considered invasive per the MMP. These species include seaside barley (Hordeum marinum) and Italian rye grass (Festuca perennis), which account for 5.9% and 2.5% respectively, on average across

Project Wetland Mitigation Condition Assessment v H. T. Harvey & Associates the site. If these species are removed from the invasive species list, all of the wetland groups and the enhanced wetlands would meet their absolute cover of invasive species Year 5 performance criteria. These species should be considered for removal from the invasive species list since removing these species from the wetlands, either by manual or chemical means, is likely to cause more harm than benefit to the mitigation wetlands. Most wetland groups met the Year 5 performance criteria of having hydric soils and had evidence of wetland hydrology.

However, we note that elevations within the wetland groups were not consistent, with some areas not supporting ponding through the spring. This led to a lack of native hydrophytic vegetation in portions of the mitigation wetlands. Ponding and soil saturation was observed in some portion of each wetland area. Wetland Groups 1, 2, and 4 generally had more ponding than Wetland Groups 3, 5, and 6 and ponding remained present for a longer period of time in Wetland Groups 1, 2, and 4, than Wetland Groups 3, 5, and 6.

All wetland groups met the health and vigor Year 5 performance criteria and the expanded wetlands, and the enhanced wetlands met the species richness Year 5 performance criteria (evaluated at the landscape scale).

Paspalum TE turf grass was observed interspersed with other vegetation during vegetation cover monitoring, and small patches were observed during the Paspalum survey. These patches of Paspalum TE were interspersed with other wetland plants and did not appear to be creating large monocultures within the wetlands. Some buffer areas were dominated by native grasses, primarily creeping wildrye (Elymus triticoides). However, many of the buffer areas lacked native grasses, but Paspalum TE was generally not present in these areas.

Next Steps Condition 33 of the RWQCB permit states:

The Applicant is responsible for providing additional compensatory mitigation in the event that the mitigation wetlands described in the body of this Certification either: are not constructed within 12 months of the Project’s first impacts to waters of the State; fail to attain their year 5 performance standards, as presented in the MMP (including the successful creation of 4 acres of wetland expansion and 0.20 acres of wetland enhancement), or have maintenance or attainment with their performance standards compromised by the performance of activities that are prohibited by the deed restrictions over these mitigation sites; or fail to have a deed restriction executed and recorded over the mitigation sites within the time schedules required by Condition 32 of this Certification. For any of the mitigation wetlands that fail to attain or maintain performance standards, or fail to have a deed restriction executed, the Applicant shall provide mitigation equivalent to the originally required mitigation, plus an additional 10 percent increase in the area of mitigation for each year between the initial discharge to waters of the State and the implementation of additional mitigation.

The initial discharge for the project occurred in 2016 and the wetland mitigation areas were constructed within 12 months of the discharge. However, several requirements in this condition have not been met including that a deed restriction has not yet been recorded over the wetlands and several success criteria have not been achieved as shown in Table ES-4. Therefore, 8 years have passed with the project being out of compliance with the permits. According to Condition 33 of the RWQCB permit, a 10 percent increase in the area of the mitigation should be added each year, for a total increase in area of 80%. The project required 4.20 acres of mitigation wetlands. Therefore, 7.56 acres (4.20 + (4.20 × 0.8) of mitigation wetlands are now required. The

Project Wetland Mitigation Condition Assessment vi H. T. Harvey & Associates project included 8.03 acres of wetland expansion and 0.42 of enhancement of existing wetlands in its original construction plan, which is more than 7.56 acres. However, the total surface area of expanded jurisdictional wetlands is unknown because a Year 1 wetland delineation, required by the project permits, was not conducted.

Therefore, a wetland delineation of the expanded and enhanced wetlands should be conducted to assess how much additional wetland mitigation acreage, if any, is required to meet the permit conditions. This wetland delineation will also inform whether any of the mitigation wetlands need to be modified hydrologically to create jurisdictional wetlands.

Below we provide recommendations for maintaining the existing mitigation wetlands to help them meet the Year 5 performance criteria. Below, we do not provide recommendations for earthwork or hydrologic modifications to the mitigation wetlands because a formal wetland delineation is necessary to determine whether and what quantity of additional wetlands are needed to meet the permit conditions.

Recommendations to Bring each Wetland Group into Compliance with the MMP and Permits

All Wetland Groups:

• Manage and maintain all wetlands to meet the project’s Year 5 performance criteria through a combination of invasive plant control, site access control, and targeted revegetation, as described by wetland group, below.

Wetland Group 1:

• Remove and restore the unofficial paths within the wetlands (shown in Figure 2) by decompacting the soil and seeding or planting with native wetland plants, such as pickleweed (Salicornia pacifica) and alkali bulrush (Bolboschoenus maritimus).

• Install a deterrent to human access, such as split-rail fencing with signage, where unofficial walking or cart impacts are currently observed (Figure 2).

• Manually remove patches of invasive plants specifically including ice plant (Carpobrotus edulis) and introduced common reed (Phragmites australis subsp. australis) shown in Figure 2.

• Remove patches of Paspalum TE from the wetland shown in Figure 2.

Wetland Group 2:

• Remove and restore the unofficial path within the wetlands (shown in Figure 2) by decompacting the soil and seeding or planting with native wetland plants.

• Install a deterrent to human access, such as split-rail fencing with signage, where unofficial walking or cart impacts are currently observed (Figure 2).

Project Wetland Mitigation Condition Assessment vii H. T. Harvey & Associates

• Wetland Group 2 did not meet the invasive species criteria. The primary invasive species (per the MMP’s definition) were foxtail barley (Hordeum murinum), seaside barley, and Italian wildrye. The control of these naturalized grasses is likely not practical due to their habitat and intermixing with native wetland vegetation.

However, these species are typical of drier, less inundated wetlands and uplands. Therefore, ways to increase ponding and duration of ponding should be considered to exclude these invasive grasses.

Wetland Group 3:

• Manually remove patch of greater periwinkle (Vinca major) shown in Figure 2.

• Wetland Group 3 did not meet the invasive species criteria. The primary invasive species (per the MMP’s definition) was seaside barley a facultative wetland plant. The control of these naturalized grasses is likely not practical due to their habitat and intermixing with native wetland vegetation. Therefore, we do not recommend control of this species at this time.

Wetland Group 4:

• Remove and restore the unofficial path within the wetlands (shown in Figure 2) by decompacting the soil and seeding or planting with native wetland plants.

• Install a deterrent to human access, such as split-rail fencing with signage, where unofficial walking or cart impacts are currently observed (Figure 2).

Wetland Group 5:

• Remove and restore the unofficial path within the wetlands (shown in Figure 2) by decompacting the soil and seeding or planting with native wetland plants.

• Install a deterrent to human access, such as split-rail fencing with signage, where unofficial walking or cart impacts are currently observed (Figure 2).

• Wetland Group 5 did not meet the invasive species criteria. The primary invasive species (per the MMP’s definition) foxtail barley, rattail sixweeks grass (Festuca myuros), and Italian rye grass. The control of these naturalized grasses is likely not practical due to their habitat and intermixing with native wetland vegetation.

However, these species are typical of drier, less inundated wetlands and uplands. Therefore, ways to increase ponding and duration of ponding should be considered to exclude these invasive grasses.

Wetland Group 6:

• Wetland 6 did not meet the hydric soil criteria. Additionally, it was dominated by a combination of obligate wetland plants (primarily pickleweed) and facultative upland plants (primarily sickle grass [Parapholis incurva]) which highlights that much of the site may not have the hydrology to support wetlands plants, even if some areas do. Following the wetland delineation, if additional acreage is required, consider modifying the hydrology and topography to create a wetland that meets the hydric soil criteria and would support additional wetland vegetation.

Project Wetland Mitigation Condition Assessment viii H. T. Harvey & Associates

Enhanced Wetlands:

• Plant additional native wetland plants within the enhanced wetland areas to increase native wetland plant diversity. Additional species could include alkali bulrush, field sedge (Carex praegracilis), creeping wildrye, meadow barley (Hordeum brachyantherum), California bulrush (Schoenoplectus californicus), salt sand spurry (Spergularia marina), and broadleaf cattail (Typha latifolia). The species should be planted according to each species tolerance to inundation. For example, California bulrush and broadleaf cattails should be planted in areas that are inundated for long periods of time, whereas creeping wildrye should be installed that are seasonally inundated.

Project Wetland Mitigation Condition Assessment ix H. T. Harvey & Associates

Table of Contents

Introduction Permit Numbers Project Background and Mitigation Requirement

Methods Biological Metrics

Absolute Cover Health and Vigor Species Richness Paspalum Survey

Physical Metrics Presence of Hydric Soils Salinity Hydrology CRAM Assessment

General Observation Photo Documentation

Results Biological Metrics

Absolute Cover Health and Vigor Species Richness

Paspalum Survey Physical Metrics

Presence of Hydric Soils Salinity Hydrology

General Observations Photo Documentation

Discussion Next Steps

References

Figures Figure 1. Vicinity Map Figure 2. Expanded and Enhanced Wetland Areas with Ponded Areas, Invasive Species Patches, and Photo

Documentation Locations Figure 3. Native Wetland Species Richness of Expanded Wetlands by Number of Quadrats Sampled Figure 4. Native Wetland Species Richness of Enhanced Wetlands by Number of Quadrats Sampled

Tables Table 1. Project Impacts on Waters of the United States by Activity Type Table 2. Compensatory Wetland Mitigation Quantities Table 3. MMP Year 5 Success Criteria (ICF International 2016) Table 4. Number of Vegetation Monitoring Quadrats per Wetland Group Table 5. Health and Vigor Categories (ICF International 2016)

Project Wetland Mitigation Condition Assessment x H. T. Harvey & Associates

Table 6. Summary of Year 5 Performance Criteria Met by Wetland Group Table 7. Percent Cover of Vegetation Table 8. Health and Vigor Ratings of Vegetation with Standard Error Table 9. Species Richness Table 10. Presence of Hydric Soils Table 11. Water Salinity Table 12. Soil Salinity Table 13. Average Ponding Depth by Expanded Wetland Group

Appendices Appendix A. Figure 5 of the Project’s MMP ....................................................................................................... A-1 Appendix B. Absolute Cover by Wetland Group and Species ......................................................................... B-1 Appendix C. Absolute Cover Sampling Effort Verification .............................................................................. C-1 Appendix D. Photo Documentation .................................................................................................................... D-1

List of Preparers Max Busnardo, M.S., Principal, Restoration Ecologist Gavin Archbald, M.S., Senior Associate Restoration Ecologist Ryan Hegstad, M.S., Senior Restoration Ecologist Dana DeLew, B.S., Restoration Field Biologist

Project Wetland Mitigation Condition Assessment 1 H. T. Harvey & Associates

Introduction

Permit Numbers

• U.S. Army Corps of Engineers (USACE) File No. 2013-00109S

• Regional Water Quality Control Board (RWQCB) Water Quality Certification Site No. 02-01-C0698 [bkw], California Integrated Water Quality System Place No. 802332]

• U. S. Fish & Wildlife Service Informal Consultation on the Reconfiguration of the Palo Alto Municipal Golf Course in the City of Palo Alto (the City), Santa Clara County, California.

Project Background and Mitigation Requirement

The City constructed the City of Palo Alto Municipal Golf Course Reconfiguration Project (project) in 2016 and 2017 at the Baylands Golf Links golf course located at 1875 Embarcadero Road in Palo Alto, California (Figure 1). Reconfiguration of the golf course required permanent and temporary impacts to wetlands/waters of the United States and State located at the project site (Table 1). Permits for the project were issued by RWQCB and USACE and USFWS was consulted on potential effects of the project to federally listed species.

The project included 8.03 acres of wetland expansion and 0.42 of enhancement of existing wetlands at the golf course project site. Of this amount, the project’s permits require at least 4.0 acres of wetland expansion (i.e., wetland creation) and 0.20 acres of wetland enhancement to compensate for the project’s impacts (Table 2).

The plan to expand and enhance the project wetlands is provided in the project’s Mitigation and Monitoring Plan (MMP) (ICF International 2016). Herein we use the term “wetland expansion” for consistency with the terminology in the MMP and permits; this term refers to the conversion of uplands to wetlands (i.e., wetland creation/establishment).

Table 1. Project Impacts on Waters of the United States by Activity Type

Project Impact Impact (acres)

Temporary impacts to non-tidal brackish marsh 0.29

Permanent impacts to non-tidal brackish marsh 1.36

Table 2. Compensatory Wetland Mitigation Quantities

Mitigation Type Required Amount to Compensate for Impacts (acres)

Proposed Wetland Expansion and Enhancement (acres)

Expansion (Creation/Establishment)

4.00 8.03

Enhancement 0.20 0.42

Total 4.20 8.45

M a rs h R d

Laurel Elementary

School

Lorelei Manor Suburban Park

Allied Arts Stanford Park

Friendly Acres

West Atherton

Atherton

Menlo Park

North Fair Oaks

Stanford University

West Menlo

Central Portola Valley

Sharon Heights

Stanford Hills

West Menlo Park

Stanford Weekend Acres

Ladera

W Bayshore

R d

Dana Ave

Embar cad ero Rd

D um ba rt on

Br g

Bayf ron t E xp y

Menlo Oaks

Bayfront

The Willows

Flood Triangle

East Palo Alto

Palo Alto

A do be

C re e k

S ta nf or d A ve

S C al if or ni a A ve

Ca lifornia St

L o s A l to s A v e

Villa St

L a C re s ta D r

Louis Rd

Bryant St

Em erson

St M iddlefield

Rd

W Middlefield Rd

O re go n E xp y

El Camino Real

W El Camino

Real

P a g e M il l R d

Central Expy

F oo th ill

E x p y

S a n A n to n io

R d

Shoreline Golf Links

Stanford University

Stanford

Los Altos

Mountain View E Evelyn Ave

M of fe tt B lv dN S h o re li n e B lv d

E Middlefield

R d

W V a lle y F w y

SACRAMENTO

MARIN

NAPA

SOLANO

CONTRA COSTA

SANTA CLARA

SAN JOAQUIN

ALAMEDA

SAN MATEO

SANTA CRUZ

Santa Rosa

Sacramento

Napa

Fairfield

San Rafael

Martinez

San Francisco

Oakland

Stockton

Redwood City San Jose

Santa Cruz

Hollister

N

P ro je ct s4

\4

-0

\R e p o rt s\

W e tla n d M iti g a tio n C o n d iti o n

A ss m n t\ W e tla n d

M iti g a tio n

C o n d iti o n A ss m n t.

a p rx

1 0 10.5

Miles±

August 2024

Palo Alto Municipal Golf Course Reconfiguration Project Wetland Mitigation Condition Assessment (4821-01)

Figure 1. Vicinity Map

Project Vicinity

California

Project Location

Project Wetland Mitigation Condition Assessment 3 H. T. Harvey & Associates

The City of Palo Alto implemented the grading, seeding, and planting to expand and enhance 8.45 acres of wetland habitat in 2016 and 2017, based on project construction submittals, change orders, completion dates provided by the City of Palo Alto (City of Palo Alto 2016) (Wadsworth Golf Construction Company 2016) and H. T. Harvey & Associates’ review of the construction contractor’s As-Built Drawings (Wadsworth Golf Construction Company 2018).

The project’s permits and MMP call for a minimum of 5 years of habitat monitoring of the 8.45 acres of expanded and enhanced wetlands. The project’s records document construction and planting in 2016 and 2017 (City of Palo Alto 2016) (Wadsworth Golf Construction Company 2016). Therefore, wetland mitigation monitoring was required in 2017 through 2021. This monitoring was not performed by the City. In 2023, the City prepared and provided biological observations of the project's mitigation wetlands (Golfauna 2023). In 2024, the City retained H. T. Harvey to perform habitat monitoring required in the MMP (H. T. Harvey 2024).

Through email communications with the City, RWQCB has indicated that the purpose of the 2024 monitoring is to determine the existing condition of the mitigation wetlands and does not constitute an annual monitoring report (Wines pers. comms 2024). The RWQCB has also indicated that the failure to monitor the mitigation wetlands and provide other required report submittals has triggered the need for additional mitigation wetlands, as specified in RWQCB permit Condition 33. Finally, the RWQCB has requested a plan be developed to correct any deficiencies in the performance of the existing mitigation wetlands (Wines pers. comms. 2024).

Therefore, this report serves to compare the existing conditions of the site to the Year 5 performance criteria set in the MMP (Table 3) using the annual monitoring methods in the MMP. In addition, this report provides H. T. Harvey’s calculation of the amount of additional mitigation necessary to satisfy RWQCB permit Condition 33 and makes conceptual recommendations for next steps to make progress toward meeting performance criteria where criteria were not met.

Table 3. MMP Year 5 Success Criteria (ICF International 2016)

Monitoring Metric Year 5 Performance Criteria

Biologic Metrics

Absolute cover of native hydrophytic plants >70%

Absolute cover of invasive species <15%

Health and vigor >90% in good or fair condition

Species richness At least 5 native hydrophytic species

Physical Metrics

Hydric Soils Presence of hydric soils

CRAM Assessment CRAM score between 90 and 95

Project Wetland Mitigation Condition Assessment 4 H. T. Harvey & Associates

Methods

Per the project’s MMP, the success of the project will be evaluated throughout the 8.45 acres of expanded and enhanced wetlands based on:

• absolute cover of native hydrophytic plants, invasive plant cover, plant health and vigor, and plant species richness using quadrats,

• hydrologic monitoring,

• hydric soil monitoring,

• salinity monitoring,

• and observational TE Paspalum (Paspalum vaginatum) (i.e., a patented variety of seashore paspalum used as the golf course turf grass) monitoring within the mitigation wetlands and 10-foot buffers.

• California Rapid Assessment Method (CRAM) Assessment

The location of the 8 acres of expanded and 0.45 acre of enhanced wetlands is provided in project’s MMP (ICF International 2016) (Figure 2). H. T. Harvey restoration ecologists monitored the 8.45 acres of expanded and enhanced wetlands at the site according to the methods proposed in the project’s MMP with minor deviations described in the subsections below. The proposed minor deviations to the monitoring methods were presented to RWQCB (H. T. Harvey 2024).

Additionally, we sought to determine how individual wetland areas composing the 8.45 acres compared to the performance criteria to inform our maintenance recommendations. In order to identify whether portions of the 8.45-acre mitigation wetland area met the MMP’s Year 5 success criteria, we divided the expanded and enhanced wetland areas into spatially contiguous areas referred to as “wetland groups” and analyzed these wetlands groups separately and combined (Figure 2). Specifically, each wetland group is located within the same depressional area below the elevation of the surrounding golf course. The wetland groups cover the full extent of the proposed expanded and enhanced mitigation wetlands shown in Figure 5 in the project’s MMP (ICF International 2016; Attachment A). Enhanced wetlands were sampled separately from expanded wetlands since they provide different levels of mitigation credit, as required by the MMP. Because the enhanced wetlands are relatively small compared to expanded wetlands, the enhanced wetlands were analyzed together as one group.

We compared the results of each monitoring metric for each wetland group to the Year 5 performance criteria set in the MMP.

ð ð ð ð ð ð

Expanded Wetland Group 1

Expanded Wetland Group 2

Expanded Wetland Group 4

Expanded Wetland Group 5

Expanded Wetland Group 6

Expanded Wetland Group 3

PP-16

PP-15

PP-1

PP-3

PP-4

PP-2

PP-5

PP-6

PP-8

PP-7

PP-9

PP-11

PP-10

PP-12

PP-13

PP-14

N

P ro je ct s4

\4

-0

\R e p o rt s\

W e tla n d M iti g a tio n C o n d iti o n

A ss m n t\ W e tla n d

M iti g a tio n

C o n d iti o n A ss m n t.

a p rx

200 0 200100

Feet±

August 2024 Palo Alto Municipal Golf Course Reconfiguration Project Wetland Mitigation Condition Assessment (4821-01)

Figure 2. Expanded and Enhanced Wetland Areas with Ponded Areas, Invasive Species Patches and Photo Documentation Locations

Wetland Group

Ponded and Saturated Areas

Expanded Wetlands (8.03 ac) (ICF International 2016)

Enhanced Wetlands (0.42 ac) (ICF International 2016)

Undisturbed Existing Wetlands (1.33 ac) (ICF International 2016)

Photo Point ð Drains

Soil Pit

Unofficial Trail

Invasive Species

Perennial Pepperweed (Lepidium latifolium)

Alkali Russian Thistle (Salsola soda)

Iceplant (Carpobrotus edulis)

Paspalum TE (Paspalum vaginatum)

Common Reed (Phragmites australis subsp. australis)

Greater periwinkle (Vinca major)

ICF International 2016. Palo Alto Municipal Golf Course Reconfiguration Project Mitigation and Monitoring Plan.

Prepared for City of Palo Alto June 14

PP-9

Project Wetland Mitigation Condition Assessment 6 H. T. Harvey & Associates

Biological Metrics

Absolute Cover

Absolute cover monitoring occurred on May 1, 2, and 30, 2024. The MMP requires monitoring absolute cover of native hydrophytic (i.e., wetland) and invasive vegetation by placing the quadrats along linear transects.However, this method of locating quadrats runs the risk of biased sampling that may not be representative of the wetland sample frame. Therefore, H. T. Harvey restoration ecologists altered these methods slightly to ensure that the wetlands were representatively sampled. Specifically, we placed the quadrats in stratified random locations within each wetland group, instead of along linear transect, to better capture the range of conditions across each wetland group. This method was described to RWQCB prior to implementation (H. T. Harvey 2024). The number of quadrats in each wetland group is proportional to each wetland group’s size (Figure 2) (Table 4). In total, 10 quadrats were sampled in the enhanced wetlands, and 60 quadrats were sampled in the expanded wetlands (Table 4). Plants were identified to the species level using The Jepson Manual 2nd edition (Baldwin et al. 2012) and assigned a wetland indicator rating using The National Wetland Plant List (USACE 2022). Wetland indicator, native status, and invasiveness ratings (i.e., whether plants were invasive per the definition in the MMP) were assigned to each species documented in quadrats.

The MMP defines invasive plants as categorized as “high” or “moderate” risk, as defined in the California Invasive Plant Council’s (Cal-IPC’s) Invasive Plant Inventory (Cal-IPC 2024). The average percent cover by native wetland species and invasive species were calculated and compared to the Year 5 performance criteria set in the MMP (Table 3). Results were calculated for each wetland group separately as well as for the expanded wetland groups combined. To ensure that sufficient sampling was conducted, the total cover of wetland species was calculated for each plot, and the cumulative means were graphed with the standard error. The number of quadrats was considered to be sufficient when the cumulative mean line flattened.

Table 4. Number of Vegetation Monitoring Quadrats per Wetland Group

Wetland Group Number of Quadrats

Expanded Wetland Group 1 18

Expanded Wetland Group 2 17

Expanded Wetland Group 3 4

Expanded Wetland Group 4 11

Expanded Wetland Group 5 5

Expanded Wetland Group 6 5

Enhanced Wetlands 10

Health and Vigor

Per the MMP, the health and vigor of each species present in each quadrat was monitored concurrently with absolute cover monitoring on May 1, 2, and 30, 2024 using the criteria presented in Table 5. The average health and vigor score for total, native, and invasive plant species were calculated for each wetland group; however, Project Wetland Mitigation Condition Assessment 7 H. T. Harvey & Associates per the MMP, the performance criteria were evaluated at the landscape level (i.e., for the enhanced and expanded wetlands). The health and vigor averages were compared to the Year 5 performance criteria set in the MMP (Table 3). As required by the MMP, the standard error of the health and vigor of each species was calculated.

Table 5. Health and Vigor Categories (ICF International 2016)

Rating No. Category Description

3 Good Plant has relatively long internode lengths and most or all leaves show healthy color and size, and/or <25% of plant’s aboveground growth is affected by browse damage, boron toxicity, disease, or insect infestation.

2 Fair Plant has medium to long internode lengths and most leaves show healthy color and size, and/or 25–75% of plant’s aboveground growth is affected by browse damage, boron toxicity, disease, or insect infestation.

1 Poor Plant has short internode lengths and few or some leaves show healthy color and size, and/or >75% of plant’s aboveground growth is affected by browse damage, boron toxicity, disease, or insect infestation.

Species Richness

Species richness monitoring occurred concurrently with absolute cover monitoring on May 1, 2, and 30, 2024.

As required by the MMP, species richness assessments were performed by counting all rooted plant species within each quadrat. Each rooted plant was identified to the species level using The Jepson Manual 2nd edition (Baldwin et al. 2012). Assessments were performed concurrently with absolute cover monitoring. The mean and standard error of total, native, and invasive species richness was calculated for each wetland group.

However, the performance criteria were evaluated at the landscape level (i.e., for the enhanced and expanded wetlands), as required by the MMP.

Paspalum Survey

Paspalum monitoring occurred on May 1, 2024. Paspalum TE (Paspalum vaginatum), a patented variety of nonnative seashore paspalum, is the turf grass used at the Baylands Golf Links golf course. The project was designed such that there will be at least a 10-foot buffer between the Paspalum TE turf grass and any wetlands are on site (ICF International 2016). A site-wide Paspalum TE survey was conducted to assess if any turf grass was invading the buffer areas between the golf course and the wetlands, and/or the wetlands. The entire boundary of the mitigation wetlands was walked while searching for encroaching Paspalum TE. Additionally, any Paspalum TE that was identified during the vegetation percent cover monitoring was noted. If Paspalum TE was observed in the wetlands or buffer areas, it was mapped.

Project Wetland Mitigation Condition Assessment 8 H. T. Harvey & Associates

Physical Metrics

Presence of Hydric Soils

Hydric soil monitoring occurred on May 1, 2, and 30, 2024. Soil pits were dug in nine locations across the site, with two locations in enhanced wetlands and seven locations in expanded wetlands. The soil pits were paired with a vegetation monitoring plot and were located in areas that were representative of the majority of the wetland group area. As required by the project’s MMP, the top approximately 20 centimeters (~8 inches) of the soil profile were examined for hydric soil indicators by assessing soil color and texture in each distinct horizon at each location. The soil pits were dug deeper, if needed, to assess if the soils were considered hydric or not because some diagnostic features were only present at depths below 8 inches. Diagnostic features of hydric soils include the numerous indicators defined and described by the National Technical Committee for Hydric Soils. These include the presence of histosols (A1), histic epipedons (A2), depleted matrix (F3), redox depressions (F8), redox dark surface (F6), and mottling indicated by the presence of gleyed or bright spots of colors (in the former case, blue grays; in the latter case, orange red, or red brown) within the soil horizons observed, among other features (USACE 2008). All soil colors indicated in this report were taken under clear, sunny skies using moistened soil samples.

Salinity

Water Salinity

Water salinity was monitored on February 21, 2024. Salinity was measured in each wetland group using a refractometer in the field. This method was used instead of a conductivity meter as described in the MMP.

However, these methods are comparable. The number of water salinity measurements in each wetland group was proportional to each wetland group’s size. No water salinity samples were taken from within the enhanced wetlands. However, the enhanced wetland hydrology is continuous with that of the expanded wetlands such that the salinity levels would be similar to that of the neighboring expanded wetlands. The average salinity of each wetland group and the entire mitigation site was calculated along with the standard error.

Soil Salinity

Soils for soil salinity monitoring was collected concurrently with hydric soil monitoring on May 1, 2, and 30, 2024. Soil salinity was measured within the upper 6 inches of the wetland soil profile using the saturated soil paste method and a refractometer in representative locations. This method was used rather than a soil salinity meter as described in the MMP. However, these methods are comparable. Soil paste samples were collected in the same nine locations at the hydric soil sampling pits. The accuracy of the saturated soil paste method is comparable to the use of a soil salinity meter. To measure salinity, the soil pore water is squeezed onto the refractometer through a syringe; the syringe includes filter paper to remove soil particles from the pore water.

Project Wetland Mitigation Condition Assessment 9 H. T. Harvey & Associates

Hydrology

The MMP calls for monitoring site hydrology using staff gages. The City has not installed staff gages. Therefore, hydrological indicators (e.g., ponding, surface soil saturation) were mapped during site visits and assessed according to the USACE Wetlands Delineation Manual Arid West Regional Supplement (USACE 2008). The extent of ponded and saturated soil was mapped on February 21, 2024 and was observed again on March 6, April 19, and May 1, 2024. The depths of ponding in these locations were measured on May 1, 2024.

CRAM Assessment

A California Rapid Assessment Method (CRAM) assessment is required by the MMP. However, a CRAM assessment was not performed because a baseline CRAM assessment to compare it to was never performed.

Moreover, some of the key CRAM metrics from the depressional wetland module that would be expected to change over time are captured by the quantitative quadrat vegetation monitoring summarized above; these metrics include native and invasive species cover. This change in methods was approved by RWQCB (Wines pers. comms. 2024).

General Observation

The monitoring ecologists noted any observations of items that may not align with the project’s objectives during each of the monitoring visits noted above. These items could include unofficial walkways, patches of invasive species, or otherwise.

Photo Documentation

Photo documentation was completed from 15 locations across the mitigation wetlands at the Palo Alto Golf Course. These photo documentation locations were chosen to be representative of each wetland groups’ conditions. Photos were collected on February 21 and April 22, 2024.

Project Wetland Mitigation Condition Assessment 10 H. T. Harvey & Associates

Results

Overall, the expanded and enhanced mitigation wetlands did not meet the Year 5 performance criteria, as shown in Table 6. Each performance criterion is described in detail, below.

Table 6. Summary of Year 5 Performance Criteria Met by Wetland Group

Year 5 Performance Criteria

Wetland Group

Approximate Surface Area (Acre) 1

Absolute Cover of Native Hydrophytic Plants

Absolute Cover of Invasive Species

Health and Vigor

Species Richness2

Hydric Soils

Year 5 Performance Criteria

>70% Native Hydrophytic Plant cover

<15% Invasive Plant Cover

>90% in Good or Fair Condition

At Least 5 Native Wetland Plant Species

Presence of Hydric Soils

Expanded Wetland Group 1

2.61 No Yes Yes NA3 Yes

Expanded Wetland Group 2

2.80 No No Yes NA Yes

Expanded Wetland Group 3

0.25 No No Yes NA Yes

Expanded Wetland Group 4

1.66 No Yes Yes NA Yes

Expanded Wetland Group 5

0.30 No No Yes NA Yes

Expanded Wetland Group 6

0.41 No Yes Yes NA No

All Expanded Wetland Groups

8.03 No No Yes Yes Yes

All Enhanced Wetlands

0.42 No No Yes No Yes

1 Wetland areas were calculated based on shapefiles created by ICF for the Palo Alto Golf Course Reconfiguration Project. Total expanded wetland and enhanced wetland areas are taken from the project’s MMP (ICF International 2016). A post-construction wetland delineation was not conducted to verify these areas.

2 Species Richness is assessed at the landscape level per the mitigation and monitoring plan (ICF International 2016).

3 NA = Not Applicable, Species Richness is evaluated at the landscape scale (all expanded and all enhanced wetlands) per the mitigation and monitoring plan (ICF International 2016).

Project Wetland Mitigation Condition Assessment 11 H. T. Harvey & Associates

Biological Metrics

Absolute Cover

Absolute cover of native wetland plants averaged 48.6% in the expanded wetlands and 43.3% in the enhanced wetlands (Table 7). Thus, the Year 5 performance criterion of 70% absolute cover of native wetland vegetation was not met in either the expanded or enhanced wetland areas. Additionally, no individual expanded wetland group had an average absolute percent cover of native wetland plants that met the Year 5 performance criterion of greater than 70% (Table 7). The most common native wetland plants in the expanded wetlands were pickleweed and alkali heath (Frankenia salina), and the most common native wetland plants in the enhanced wetlands were pickleweed and salt grass (Distichlis spicata). Cover by species and wetland group is presented in Appendix B. Graphs documenting sufficient sampling per wetland group by documenting the running average of native wetland vegetation by number of quadrats sampled are provided in Appendix C.

Vegetative cover of invasive plant species averaged 15.9% in the expanded wetlands and 21.1% in the enhanced wetlands, both which do not meet the Year 5 performance criteria of less than 15% absolute cover of invasive plants. Average absolute cover of invasive vegetation is presented by wetland group in Table 7. The most common invasive plants in the expanded wetlands were seaside barley and Italian rye grass, and the most common invasive plants in the enhanced wetlands were foxtail barley and ripgut brome (Bromus diandrus). Cover of invasive vegetation presented by wetland group and species is shown in Appendix B. Patches of invasive plants that were not encountered during absolute cover monitoring were mapped. These species included ice plant (Carpobrotus edulis), introduced common reed (Phragmites australis subsp. australis), and greater periwinkle (Vinca major) (Figure 2).

Health and Vigor

The overall average health and vigor scores for the expanded wetlands and enhanced wetlands were 2.9 and 3.0, respectively, both of which equate to a rating of “good”. No wetland groups had an average rating of less than 2.8. Therefore, the success criterion of at least 90% of vegetation in good or fair condition was met. Health and vigor ratings are presented by wetland group and species in Table 8.

Species Richness

The total species richness for native wetland plants was 10 in expanded wetlands and 4 in enhanced wetlands (Table 9) (Figures 3 and 4). The Year 5 success criterion for species richness calls for at least five native wetland species to be present in the expanded and the enhanced wetlands. Therefore, the Year 5 performance criterion was met for the expanded wetlands, but not the enhanced wetlands. Species richness was higher for all types of vegetation in expanded wetlands than in enhanced wetlands, likely due to the larger area covered by the expanded wetlands. The 10 native wetland species observed in the expanded wetlands were alkali bulrush, field sedge, salt grass, alkali heath, creeping wildrye, meadow barley, pickleweed, California bulrush, salt sand spurry, Project Wetland Mitigation Condition Assessment 12 H. T. Harvey & Associates

Table 7. Percent Cover of Vegetation Year 5

Performance Criteria

Expanded Wetland Group 1

Expanded Wetland Group 2

Expanded Wetland Group 3

Expanded Wetland Group 4

Expanded Wetland Group 5

Expanded Wetland Group 6

Average Expanded Wetlands

Average Enhanced Wetlands

Overall Average

Average Native Wetland Vegetation

> 70% 58.8 54.4 29.5 48.1 17.2 37.6 48.6 43.3 47.8

Average Invasive Vegetation

< 15% 5.1 26.2 27.0 13.0 30.8 2.0 15.9 21.1 16.6

Table 8. Health and Vigor Ratings of Vegetation with Standard Error

Common Name Scientific Name

Expanded Wetland Group 1

Expanded Wetland Group 2

Expanded Wetland Group 3

Expanded Wetland Group 4

Expanded Wetland Group 5

Expanded Wetland Group 6

Average Expanded Wetlands

Average Enhanced Wetlands

Bentgrass Agrostis sp.

Fat-hen Atriplex prostrata 21 3±0

31 2.8±0.2 3±0

Wild oat Avena fatua

31 31

Common beet Beta vulgaris

Alkali bulrush Bolboschoenus maritimus

Black mustard Brassica nigra

Rescue grass Bromus catharticus

Ripgut brome Bromus diandrus 31 3±0

31 31 3±0 3±0

Soft chess Bromus hordeaceous

3±0

2.5±0.5 2.8±0.2 3±0

Foxtail chess Bromus madritensis

Field sedge Carex praegracilis 3±0 3±0

3±0 3±0

Brass buttons Cotula coronopifolia

2.9±0.1 3±0 31 3±0 3±0 31 2.9±0.1 21

Bermuda grass Cynodon dactylon

Salt grass Distichlis spicata 3±0 3±0 3±0

31 3±0 3±0

Blue wildrye Elymus glaucus 3±0 31

Beardless wildrye Elymus triticoides

Rattail sixweeks grass Festuca myuros

31 31 3±0 31

Italian rye grass Festuca perennis 3±0 3±0 3±0 31 3±0 3±0 31

Alkali heath Frankenia salina 3±0 3±0

3±0 31 31 3±0 3±0

Wild geranium Geranium dissectum

Bristly oxtongue Helminthotheca echiodies

31 3±0 31

Meadow barley Hordeum brachyantherum

Seaside barley Hordeum marinum 3±0 3±0 3±0 3±0 31 3±0 3±0 31

Foxtail barley Hordeum murinum

31 31 3±0 3±0

Prickly lettuce Lactuca serriola 31

Perennial pepperweed

Lepidium latifolium

Cheeseweed Malva parviflora

Bur clover Medicago polymorpha

31 3±0

Yellow sweetclover Melilotus indicus 31

Sickle grass Parapholis incurva 3±0 3±0

31 3±0 3±0 3±0

Paspalum Paspalum TE 3±0

Cut leaf plantain Plantago coronopus

3±0 3±0 31

31 3±0

Rabbitsfoot grass Polypogon monspeliensis

3±0 3±0 3±0 3±0 3±0 3±0 3±0 3±0

Curly dock Rumex crispus

31 31 31

Pickleweed Salicornia pacifica 2.9±0.1 2.9±0.1 31 2.7±0.2 3±0 3±0 2.9±0 3±0

Alkali Russian thistle Salsola soda 31 31 31 3±0 31 3±0 31

California bulrush Schoenoplectus californicus

Spiny sowthistle Sonchus asper 31 31

3±0 3±0 3±0

Salt sand spurry Spergularia marina 3±0 31 31 3±0 31 31 3±0

Broadleaf cattail Typha latifolia

Average Total 2.9±0.02 3.0±0.01 3.0±0 2.8±0.04 3.0±0 3.0±0.03 2.9±0 3±0.02 Average Native

Wetland Vegetation

2.9±0.06 3±0.02 3±0 2.8±0.12 3±0 3±0 2.9±0 3±0

Average Total Invasive Vegetation

3±0 3±0 3±0 3±0 3±0 3±0 3±0 3±0

Note: The Health and Vigor rating are as follows: 3=good, 2=fair, 1=poor 1 If no standard error is presented, the species was only observed in one quadrat in that wetland group and therefore has no standard error.

Project Wetland Mitigation Condition Assessment 13 H. T. Harvey & Associates and broadleaf cattail.