PAGC_Delineation_Report_2025_06_20r.pdf

720 University Avenue, Suite 200 Los Gatos, CA 95032 408.458.3200 www.harveyecology.com

Palo Alto Municipal Golf Course Reconfiguration Project

Wetland Delineation Report

Project #4821-02

Prepared for:

Lam Do

City of Palo Alto 250 Hamilton Avenue

Palo Alto, CA 94301

Prepared by:

H. T. Harvey & Associates

June 20, 2025 http://www.harveyecology.com/

Palo Alto Municipal Golf Course Reconfiguration Project Wetland Delineation Report i H. T. Harvey & Associates

June 11, 2025

Table of Contents

Section 1. Introduction

1.1 Permit Numbers

1.2 Project Background and Mitigation Requirements

Section 2. Survey Methods

2.1 Study Area Definition

2.2 Background Information Review and Field Survey Dates

2.3 Identification of Jurisdictional Wetlands

2.3.1 Identification of Section 404 Jurisdictional Wetlands

2.3.2 Identification of 401 Wetlands and Waters of the State

2.3.3 Wetland Mitigation Acreage Determination

Section 3. Survey Results and Discussion

3.1 Observations, Rationales, and Assumptions

3.1.1 Background Information

3.1.2 Precipitation Data

3.1.3 Site Conditions and Observations

3.1.4 Rationale for Sample Point Choice

3.1.5 Photo Points

3.2 Identification of Potential Section 404/401 Jurisdictional Wetland Habitats

3.2.1 Brackish Marsh

3.2.2 Non-Tidal Salt Marsh

3.2.3 Seasonal Wetland

3.3 Areas Not Meeting the Regulatory Definition of 404/401 Wetlands Section 4. Literature Cited

Figures

Figure 1. Vicinity Map Figure 2. Study Area Figure 3. U.S. Geological Survey Topographic Map Figure 4. National Resources Conservation Service Soils Map Figure 5. National Wetland Inventory Map Figure 6. 2024 and 2025 Ponding and Saturated Soils Map Figure 7a. Preliminary Identification of Potential Section 404/401 Jurisdictional Wetlands Figure 7b. Preliminary Identification of Potential Section 404/401 Jurisdictional Wetlands Figure 7c. Preliminary Identification of Potential Section 404/401 Jurisdictional Wetland

Tables

Table 1. Project Impacts on Waters of the United States by Activity Type Table 2. Compensatory Wetland Mitigation Quantities Table 3. Wetland Indicator Status Categories for Vascular Plants Table 4. Summary of USACE and RWQCB Jurisdictional Wetlands within the Study Area Table 5. Summary of Sample Point Locations and Results Table 6. Coordinates and Rationale for Photo Points

Project Wetland Delineation Report ii H. T. Harvey & Associates

Appendices

Appendix A. NRCS Soils Report ........................................................................................................................... A-1 Appendix B. Plant Species Observed .................................................................................................................... B-1 Appendix C. USACE Arid West Wetland Data Forms ..................................................................................... C-1 Appendix D. 2024 Vegetation and Soil Data ...................................................................................................... D-1 Appendix E. Photos of the Study Area ................................................................................................................. E-1 Appendix F. Aquatic Resources Table ................................................................................................................. F-1 Appendix G. Antecedent Precipitation Tool Output ........................................................................................ G-1

List of Preparers

Max Busnardo, M.S., Principal-in-charge, Senior Restoration Ecologist Kelly Hardwicke, Ph.D., Principal, Senior Plant and Wetland Ecologist Ryan Hegstad, M.S., Project Manager, Senior Restoration Ecologist Jenna Shikuzawa, M.S., Restoration Ecologist

Project Wetland Delineation Report 3 H. T. Harvey & Associates

Section 1. Introduction

1.1 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.

1.2 Project Background and Mitigation Requirements

The City of Palo Alto (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). The project’s permits and Mitigation and Monitoring Plan (MMP) 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 (ICF 2016). Condition 33 of the Regional Water Quality Control Board (RWQCB) permit also requires additional wetland mitigation as follows: “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 to waters of the U.S./State occurred in 2016.

The project design included 8.03 acres of wetland expansion and 0.42 of enhancement of existing wetlands at the golf course project site (Figure 2).

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

The plan to expand and enhance the project wetlands is provided in the project’s MMP (ICF 2016). In summary, the City implemented grading, seeding, and planting to attempt to expand and enhance 8.45 acres of wetland habitat in 2016 and 2017 (City of Palo Alto 2016; Wadsworth Golf Construction Company 2016; Wadsworth Golf Construction Company 2018).

Per the project’s MMP, wetland expansion included excavating fill from elevated terrain surrounding existing wetlands (approximately 2 feet in depth, extending up to approximately 125 feet), while wetland enhancement

Project Wetland Delineation Report 4 H. T. Harvey & Associates included invasive species removal within existing jurisdictional wetlands (ICF 2016). Both expanded and enhanced wetlands were hydroseeded and planted with native brackish marsh plant species such as brown-headed rush (Juncus phaeocephalus), slough sedge (Carex obnupta), and meadow barley (Hordeum brachyantherum). 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 including unofficial paths observed within expanded wetland areas (H. T. Harvey 2024).

Laurel Elementary

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Lorelei Manor Suburban Park

Allied Arts Stanford Park

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Palo Alto Municipal Golf Course Reconfiguration Project Wetland Delineation Report (4821-02)

Figure 1. Vicinity Map

Project Vicinity

California

Project Location

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June 2025 Palo Alto Municipal Golf Course Reconfiguration Project - Wetland Delineation Report (4821-02)

Figure 2. Study Area

Study Area

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)

Imagery: Google Earth, February 2024 ICF International 2016. Palo Alto Municipal Golf Course Reconfiguration Project Mitigation and Monitoring Plan.

Prepared for City of Palo Alto June 14

Project Wetland Delineation Report 7 H. T. Harvey & Associates

The project’s permits and MMP call for a minimum of 5 years of habitat monitoring of the expanded and enhanced wetlands (hereafter referred to as mitigation wetlands). Additionally, the project’s MMP and USACE permit call for a wetland delineation in Year 1, while the project’s RWQCB permit calls for a wetland delineation in Year 5, to determine whether the mitigation wetland acreage sufficiently compensates for project impacts.

As described above, 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.

Per Condition 33 of the RWQCB permit, the amount of mitigation is required to increase by 10% for each year that successful implementation of mitigation (i.e., proper monitoring and maintenance) is deferred. Therefore, a 90% increase in wetland mitigation area is required in 2025. The project’s USACE and RWQCB 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). Therefore, the RWQCB wetland mitigation acreage requirement in 2025 is as follows: 7.60 acres (4.00 + (4.00 × 0.9)) of wetland expansion (i.e., wetland creation) and 0.38 acres of wetland enhancement (0.2 + (0.2 x 0.9) (Table 2). The project included 8.03 acres of wetland expansion and 0.42 acres of enhancement of existing wetlands in its original construction plan, which is more than 7.98 acres. The USACE permit does not include this condition; therefore, the USACE wetland mitigation acreage requirement in 2025 is 4.00 acres of wetland expansion and 0.20 of wetland enhancement (i.e., the initial mitigation acreage requirement) (Table 2).

Table 2. Compensatory Wetland Mitigation Quantities

Mitigation Type

Initial Mitigation Acreage Requirement

(acres)

Revised RWQCB Mitigation Acreage

Requirement2 (acres)

Proposed Wetland Expansion and Enhancement

(acres)

Expansion (Creation/Establishment)

4.00 7.60 8.03

Enhancement 0.20 0.38 0.42

Total 4.201 7.98 8.45 1 The USACE permit does not include the RWQCB permit condition 33; therefore, its wetland mitigation requirement in

2025 is 4.00 acres of wetland expansion and 0.20 of wetland enhancement (i.e., the initial mitigation acreage requirement).

2 Per RWQCB permit condition 33, the amount of mitigation is required to increase by 10% for each year that successful implementation of mitigation (i.e., proper monitoring and maintenance) is deferred after the initial discharge to Waters of the U.S./State. The initial discharge occurred in 2016. Therefore, a 90% increase in wetland mitigation area is required in 2025.

The purpose of this report is to document the approximate footprint of regulated wetland habitats under the jurisdiction of USACE and RWQCB within the wetland mitigation area (study area; Figure 2) and to determine whether the project meets the required wetland mitigation acreage per project permits.

Project Wetland Delineation Report 8 H. T. Harvey & Associates

Section 2. Survey Methods

2.1 Study Area Definition

We defined the study area as the boundaries of the planned wetland mitigation areas (i.e., wetland expansion and wetland enhancement areas) set forth in the project’s MMP (ICF 2016). H. T. Harvey & Associates obtained GIS shape files of the wetland mitigation areas from the City and overlaid these shapes onto the most recent Google Earth imagery (dated February 2024) (Figure 2).

2.2 Background Information Review and Field Survey Dates

Before the delineation survey was conducted, H. T. Harvey & Associates’ botanist Katherine Marlin, M.S. and restoration ecologist Jenna Shikuzawa, M.S. (hereafter referred to as ecologists) reviewed topographic maps and aerial photos of the study area from several sources, including the U.S. Geological Service (USGS) topographic map (Figure 3), Natural Resources Conservation Service (NRCS) soils map (NRCS 2025a;

Figure 4), National Wetlands Inventory (NWI) map (NWI 2025; Figure 5), Google Earth aerial photography (Google, Inc. 2025), as-built site conditions, and the Palo Alto Municipal Golf Course Reconfiguration Project Wetland Mitigation Condition Assessment (H. T. Harvey 2024).

On February 21, 2024, H. T. Harvey & Associates senior restoration ecologist, Ryan Hegstad, M.S. mapped ponding and saturated soils according to the Regional Supplement within the study area using a Geode global positioning system (GPS) unit capable of sub-meter accuracy to monitor site hydrology (H. T. Harvey 2024).

The amount of ponded surface area remained relatively consistent between February 21, March 6, and April 19, 2024. On February 25 and March 3, 2025, H. T. Harvey & Associates ecologists mapped the extent of ponding within the study area using similar methods. 2024 and 2025 winter hydrology mapping results are presented in Figure 6.

On April 23, 24 and 28, 2025, H. T. Harvey & Associates’ ecologists, Katherine Marlin and Jenna Shikuzawa, performed a technical delineation of wetlands within the study area to determine the surface area and location of USACE and RWQCB jurisdictional wetlands. The wetland delineation followed the guidelines of the Corps of Engineers 1987 Wetlands Delineation Manual (Corps Manual) (Environmental Laboratory 1987) and Regional Supplement to the USACE Wetland Delineation Manual: Arid West Region (Version 2.0) (Regional Supplement) (USACE 2008) relative to hydrophytic vegetation, hydric soils, and wetland hydrology.

2.3 Identification of Jurisdictional Wetlands

We examined the study area for topographic features, drainages, alterations to site hydrology, and areas of significant recent disturbance. A determination was then made as to whether normal environmental conditions were present at the time of the field surveys. The guidelines outlined in Section D “Routine Determination Method” of the Corps Manual as well as the updated forms, vegetation sampling methods, and hydric soil and

Project Wetland Delineation Report 9 H. T. Harvey & Associates hydrology indicators in the Regional Supplement were used to examine the vegetation, soils, and hydrology within the study area. This three-parameter approach to identifying wetlands is based on the presence of a prevalence or dominance of hydrophytic vegetation, hydric soils, and wetland hydrology.

In addition to applying these survey methods, we compiled this report in accordance with guidance provided in Updated Map and Drawing Standards for the South Pacific Division Regulatory Program (USACE 2016a) and Information Requested for Verification of Corps Jurisdiction (USACE 2016b). These documents list the information that must be submitted as part of a request for a jurisdictional determination, including:

• Vicinity map (Figure 1)

• Study area map (Figure 2)

• USGS topographic map (Figure 3)

• Soils map (Figure 4)

• NWI map (Figure 5)

• Preliminary identification of Section 404/401 jurisdictional wetlands (Figure 7)

• Soils report (Appendix A)

• Plant species observed (Appendix B)

• Data forms for wetland sample points (Appendix C)

• 2024 vegetation and soil data (Appendix D)

• Written rationale for sample point choice (Section 3.1, “Observations, Rationales, and Assumptions”)

• Color photos (Appendix E)

• Aquatic resources table (Appendix F)

• A figure showing the “Antecedent Precipitation vs. Normal Range based on NOAA's Daily Global Historical Climatology Network” (Appendix G)

This report only evaluates whether features meet the 3 parameters required for physical wetlands, and does not evaluate federal wetland jurisdiction under Sackett v. EPA or the September 2023 Conforming Rule based on connectivity or adjacency. We performed this delineation with the same protocol that ICF used for the original wetland delineation upon which the project’s MMP and permits are based.

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June 2025 Palo Alto Municipal Golf Course Reconfiguration Project - Wetland Delineation Report (4821-02)

Figure 3. USGS Topographic Map

Study Area

US Topo 7.5-minute map for Mountain View, CA and Palo Alto, CA ICF International 2016. Palo Alto

Municipal Golf Course Reconfiguration

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Figure 4. National Resources Conservation Service Soils Map

Study Area

NRCS Soil Code Description

108 - Botella-Urban land complex, 0 to 5 percent slopes

120 - Aquic Xerorthents, bay mud subtratum, 0 to 2 percent slopes

120scl - Aquic Xerorthents, bay mud subtratum, 0 to 2 percent slopes

155scl - Novato clay, 0 to 1 percent slopes, tidally flooded

Imagery: Google Earth, February 2024

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ICF International 2016. Palo Alto Municipal Golf Course Reconfiguration

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Palo Alto Municipal Golf Course Reconfiguration Project - Wetland Delineation Report (4821-02) June 2025

Study Area

National Wetland Inventory

Estuarine and Marine Deepwater

Estuarine and Marine Wetland

Freshwater Emergent Wetland

Imagery: Google Earth, February 2024 E1UBL Estuarine, Subtidal, Unconsolidated Bottom, Subtidal

E2EM1N Estuarine, Intertidal, Emergent, Persistent, Regularly Flooded

PEM1Ch Palustrine, Emergent, Persistent, Seasonally Flooded, Diked/Impounded

NWI Code Description

ICF International 2016. Palo Alto Municipal Golf Course Reconfiguration

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Figure 6. 2024 and 2025 Ponding and Saturated Soils Map

Study Area

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)

Ponding and Saturation Observed in 2024

Ponding Observed in 2025

Imagery: Google Earth, February 2024 ICF International 2016. Palo Alto Municipal Golf Course Reconfiguration

Project Wetland Delineation Report 14 H. T. Harvey & Associates

2.3.1 Identification of Section 404 Jurisdictional Wetlands

Where wetland field characteristics were present, we examined vegetation, soils, and hydrology using the Routine Determination Method outlined in the Corps Manual (Environmental Laboratory 1987) and the updated data forms, vegetation sampling methods, and hydric soil and hydrology indicators developed for the Regional Supplement (USACE 2008).

As part of H. T. Harvey & Associates’ 2024 existing conditions monitoring efforts, soil pits were dug in nine locations across the study area. As required by the project’s MMP, the top approximately 20 centimeters (i.e., ~8 inches) of the soil profile were examined for hydric soil indicators following guidelines of the Regional Supplement at each location. The average depth of soil pits was approximately 13 inches. Each soil pit was paired with a vegetation monitoring plot located in areas that were representative of adjacent wetland areas (H.

T. Harvey 2024). We revisited the majority of these soil pit locations during the 2025 technical delineation of wetlands. Vegetation and hydrology were examined and documented at each location. If vegetation was in a similar condition (i.e., species composition, wetland indicator status) compared to 2024 observations, soil features were also presumed to be similar. Therefore, soil data from 2024 was documented and no soil pit was dug at these locations. During this technical delineation, we investigated additional areas to characterize vegetation, soils, and hydrology that were not represented in the 2024 soils data.

The locations of the paired sample points corresponding with the completed Corps Manual data forms (Appendix C) are shown on Figures 7a–c. Vegetation and soil data collected in 2024 is provided in Appendix D.

Vegetation. Hydrophytic plant species are defined as species adapted to growing in soils that are saturated and/or inundated for long periods of time thereby causing low oxygen levels in the soil pore water. Plants observed at each of the sample sites were identified to species, where possible, using The Jepson Manual, Vascular Plans of California, Second Edition (Baldwin et al. 2012). The wetland indicator status of each species was obtained from the Arid West 2022 Regional Wetland Plant List (USACE 2025). Wetland indicator species are designated according to their frequency of occurrence in wetlands. The wetland indicator groups, indicator symbol, and the frequencies of occurrence of species within wetlands, provided as a percentage, are shown in Table 3. Plant species that are considered wetland species include species designated as obligate (OBL), facultative wetland (FACW), or facultative (FAC).

Table 3. Wetland Indicator Status Categories for Vascular Plants

Indicator Category Symbol Frequency (%) of Occurrence in Wetlands1

Obligate OBL >99 (Almost always is a hydrophyte, rarely in uplands)

Facultative wetland FACW 67–99 (Usually a hydrophyte but occasionally found in uplands)

Facultative FAC 34–66 (Commonly occurs as either a hydrophyte or non-hydrophyte)

Facultative upland FACU 1–33 (Occasionally is hydrophyte, but usually occurs in uplands)

Upland UPL <1 (Rarely is a hydrophyte, almost always in uplands)

Not Listed NI Considered to be an upland species 1 Based on information contained in the Corps Manual (Environmental Laboratory 1987).

Project Wetland Delineation Report 15 H. T. Harvey & Associates

A list of species for each sample site was then compiled and a visual estimate of the percent cover of plant species was made following guidance provided in the Regional Supplement. We then determined which of the sample sites supported wetland vegetation using the applicable indicator (i.e., 1-Dominance Test; 2-Prevalence Test; or 3-Morphological Adaptations) as described in the Regional Supplement.

Soils. Where possible at sample points, at least the top 16 inches of the soil profile was examined for hydric soil indicators. The National Technical Committee for Hydric Soils (NTCHS) defines a hydric soil as one formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper 12 inches of soil (NRCS 2024). Hydric soils include soils developed under sufficiently wet conditions to support the growth and regeneration of hydrophytic vegetation. In general, evidence of a hydric soil includes characteristics such as reducing soil conditions, soils with bright mottles and/or low matrix chroma, and soils listed as hydric by the U.S. Department of Agriculture (USDA) on the National Hydric Soils List (NRCS 2025b). Reducing soil conditions can also include circumstances where there is evidence of ponding for a long or very long duration. A long duration is defined as a period of inundation for a single event that ranges from 7 days to a month and very long is greater than 1 month (Environmental Laboratory 1987).

Munsell Soil Notations (Munsell 2009) were recorded for the soil matrix and mottles found in each soil sample.

The Munsell color system is based on three color dimensions: hue, value, and chroma. A brief description of each component of the system is described below, in the order they are used in describing soil color (i.e., hue/value/chroma):

1. Hue—The Munsell Soil Color Chart is divided into five principal hues: yellow (Y), green (G), purple (P), blue (B), and red (R), along with intermediate hues such as yellow-red (YR) and green-yellow (GY).

Examples of commonly encountered hue numbers include 2.5YR, 10YR, and 5Y.

2. Value—Value refers to lightness, ranging from white to grey to black. Common numerical values for value in the Munsell Soil Color Chart range from 2 for saturated soils to 8 for faded or light colors.

Hydric soils often show low-value colors when soils have accumulated sufficient organic material to indicate development under wetland conditions but can show high-value colors when iron depletion has occurred, removing color value from the soil matrix. Value numbers are commonly reported as 8/, 2.5/, and 6/.

3. Chroma—Chroma describes the purity of the color, from “true” or “pure” colors to “pastel” or “washed out” colors. Chromas commonly range from 1 to 8 but can be higher for gleys. Soil matrix chroma values that are 1 or less, or 2 or less when mottling is present, are typical of soils that have developed under anaerobic conditions. Chroma numbers are listed, for example, as /1, /5, and /8.

Information about the soil type that has been mapped within the study area was reviewed. The soil type found in the study area is shown in Appendix A (NRCS 2025a).

Project Wetland Delineation Report 16 H. T. Harvey & Associates

Hydrology. Wetland hydrology encompasses all hydrologic characteristics of areas that are periodically inundated or have soils saturated to the surface at some time during the growing season. Wetland hydrology indicators provide evidence that the site has a continuing wetland hydrologic regime. Primary indicators might include visual observation of surface water (A1), high water table (A2), soil saturation (A3), and hydrogen sulfide odor (C1). Secondary indicators might include a passing score for the FAC-neutral test (D5) and saturation visible on aerial imagery (C9). Each of the sample points was examined for positive field indicators (primary and secondary) of wetland hydrology, following the guidance provided in the Regional Supplement.

2.3.2 Identification of 401 Wetlands and Waters of the State

The Porter-Cologne Water Quality Control Act (Porter-Cologne) broadly defines waters of the State as “any surface water or groundwater, including saline waters, within the boundaries of the state.” Because Porter- Cologne applies to any water, whereas the Clean Water Act applies only to certain waters, California’s jurisdictional reach overlaps and may exceed the boundaries of waters of the U.S. For example, Water Quality Order No. 2004-0004-DWQ states that “shallow” waters of the State include headwaters, wetlands, and riparian areas.

On April 2, 2019, the State Water Resources Control Board adopted the State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State. In these new guidelines, wetland-upland boundaries for wetlands comprising waters of the State should be set using the USACE delineation framework (Environmental Laboratory 1987, USACE 2008), with one important distinction. Some areas in California function as wetlands despite lacking abundant wetland vegetation. For example, non-vegetated playas, tidal flats, and some types of seasonal wetlands provide a variety of wetland functions, including water filtration, groundwater recharge, and the support of wetland wildlife. While USACE procedures require 5% vegetative cover to be considered a wetland rather than “other waters”, the RWQCB has determined that no such minimum vegetative cover is necessary for an area to be considered a wetland under the State Wetland Definition.

2.3.3 Wetland Mitigation Acreage Determination

Based on the survey methods described above, we mapped the USACE and RWQCB jurisdictional wetlands within the study area using a Geode GPS unit with sub-meter accuracy. We found in the field that small portions of expanded wetlands mitigation were constructed by the City slightly beyond the study area. In those cases, we mapped those expanded wetland areas as well because they were constructed by the project. Post-survey data processing included removing mapped wetlands from the undisturbed, existing wetlands footprint from the study area (Figure 2) using ArcGIS Pro (ESRI). Per the project’s MMP, undisturbed existing wetlands are not included within the mitigation wetland footprint or acreage; therefore, any wetlands that were mapped within these areas were excluded. These areas occur within existing wetlands where minor project activities including non-native vegetation removal and native hydroseeding were carried out (ICF 2016). Additionally, unvegetated, unofficial pathways were excluded from the study area using imagery from January and February 2024 (ESRI 2025; Google, Inc. 2025) and ArcGIS Pro (ESRI). These areas are frequently used by visitors and do not meet the restoration goals of the project (See Section 3.3 for more information). The total acreage of

Project Wetland Delineation Report 17 H. T. Harvey & Associates expanded and enhanced wetlands was then compared to the wetland mitigation acreage required by project permits.

Project Wetland Delineation Report 18 H. T. Harvey & Associates

Section 3. Survey Results and Discussion

The following vegetation/land cover types were mapped within the study area: (1) brackish marsh (indicated as “BM” on Figures 7b and c), (2) non-tidal salt marsh (indicated as “NTSM” on Figures 7b and c), and (3) seasonal wetland (indicated as “SW” on Figures 7a–c). Twenty-two sample points (SPs) were examined to identify jurisdictional features (Figures 7a–c; Appendix C). Within the study area, approximately 8.48 ac of jurisdictional wetlands potentially regulated by USACE and regulated by RWQCB were identified (Table 4). Of the 8.48 ac, 8.13 ac were identified within the project’s expanded wetland area and 0.35 ac were located within the project’s enhanced wetland area (Table 4). Therefore, the USACE wetland mitigation acreage requirement of at least 4.0 ac of expanded wetlands and 0.20 ac of enhanced wetlands has been met. The RWQCB wetland mitigation acreage requirement of at least 7.60 ac of expanded wetlands has also been met (8.13 ac of wetlands were created onsite). However, the RWQCB enhanced wetland mitigation acreage requirement of at least 0.38 ac has not been met (0.35 ac total), indicating that 0.03 ac of enhanced wetlands are no longer wetlands and could be considered a project impact. The project initially required a 3:1 mitigation ratio to offset permanent impacts. Therefore, H. T. Harvey & Associates judges that an additional 0.09 ac of created wetlands (0.03 x 3) should be required by the project. The project exceeded its RWQCB expanded wetland mitigation acreage requirement by approximately 0.53 ac—which is approximately 5 times more than the 0.09 ac of additional wetland creation required by the project. Because the 0.09 ac of expanded wetlands provide a greater ecological lift than 0.03 ac of enhanced wetlands would have, we consider the mitigation acreage for these unanticipated enhanced wetland impacts to be met.

The results of the delineation are described below.

Table 4. Summary of USACE and RWQCB Jurisdictional Wetlands within the Study Area

Habitat Type Acres

Brackish Marsh 0.13

Non-Tidal Salt Marsh 5.83

Seasonal Wetland 2.53

Total Section 404/401 Wetlands 8.481

Total Section 404/401 Wetlands within Expanded Wetland Area 8.13

Total Section 404/401 Wetlands within Enhanced Wetland Area 0.35 1 Totals do not sum correctly to the 0.01th acre due to rounding error.

Project Wetland Delineation Report 19 H. T. Harvey & Associates

3.1 Observations, Rationales, and Assumptions

Site conditions observed during the delineation survey are reported here, along with pertinent background information and precipitation data.

3.1.1 Background Information

The preliminary delineation assumes that normal circumstances prevailed at the time of the April 2025 surveys, and results are based upon the conditions present at the time of the survey. The survey was performed using the “Routine Method of Determination” using three parameters, as outlined in the Regional Supplement.

The study area includes the expanded (8.03 ac) and enhanced (0.42 ac) wetlands within the Baylands Golf Links golf course. Elevations within the study area range from approximately 0–9 feet North American Vertical Datum of 1988 (NAVD88) (Google Inc. 2025). The study area is hydrologically separated from the San Francisco Bay to the north and San Francisquito Creek to the west and is located within the San Francisco Bay Estuaries-Frontal San Francisco Bay sub watershed (12-digit Hydrologic Unit Code 180500041001).

SW-01

SW-02

PP-1

SP-01

SP-02

37.45499098, -122.11764277

N

P ro je ct s4

\4

-0

\0

\R e p o rt s\

W e tla n d D e lin e a tio n

\W e tla n d D e lin e a tio n

.a p rx

Figure 7a. Preliminary Identification of Potential Section 404/401 Jurisdictional Wetlands

Palo Alto Municipal Golf Course Reconfiguration Project -Wetland Delineation Report (4821-02)

June 2025

Study Area

Expanded Wetlands (8.03 ac) (ICF International 2016)

Enhanced Wetlands (0.42 ac) (ICF International 2016)

Photo Points

Sample Points

Section 404/401 Jurisdictional Wetlands

Seasonal Wetland (2.53 ac)

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

Prepared for City of Palo Alto June 14

Imagery: Google Earth, February 2024

Wetland Type Label Acres

Seasonal Wetland SW-01 <0.01

Seasonal Wetland SW-02 0.36

120 0 12060

Feet± 1 inch = 120 feet

BM-01

BM-02

NTSM-01

NTSM-02

NTSM-03

NTSM-04

NTSM-05

NTSM-06

NTSM-07

NTSM-08

SW-03

SW-04

SW-05

SW-06

SW-15

SW-14

SW-07

SW-13

SW-12

SW-10

SW-16

SW-09

SW-11

SW-08

SW-17

SW-20

SW-18

SW-19

PP-2

PP-3

PP-4a

PP-4b

PP-5

SP-03 SP-04

SP-05

SP-06

SP-07

SP-08

SP-09

SP-10

SP-11

SP-21

SP-22

N

P ro je ct s4

\4

-0

\0

\R e p o rt s\

W e tla n d D e lin e a tio n

\W e tla n d D e lin e a tio n

.a p rx

Figure 7b. Preliminary Identification of Potential Section 404/401 Jurisdictional Wetlands

Palo Alto Municipal Golf Course Reconfiguration Project - Wetland Delineation Report (4821-02) June 2025

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

Prepared for City of Palo Alto June 14

Study Area

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 Points

Sample Points

Section 404/401 Jurisdictional Wetlands

Brackish Marsh (0.13 ac)

Non-Tidal Salt Marsh (5.83 ac)

Seasonal Wetland (2.53 ac)

Imagery: Google Earth, February 2024

Wetland Type Label Acres

Brackish Marsh BM-01 0.01

Brackish Marsh BM-02 <0.01

Non-Tidal Salt Marsh NTSM-01 0.09

Non-Tidal Salt Marsh NTSM-02 0.04

Non-Tidal Salt Marsh NTSM-03 0.04

Non-Tidal Salt Marsh NTSM-04 1.29

Non-Tidal Salt Marsh NTSM-05 <0.01

Non-Tidal Salt Marsh NTSM-06 <0.01

Non-Tidal Salt Marsh NTSM-07 <0.01

Non-Tidal Salt Marsh NTSM-08 0.02

Seasonal Wetland SW-03 <0.01

Seasonal Wetland SW-04 0.01

Seasonal Wetland SW-05 <0.01

Seasonal Wetland SW-06 <0.01

Seasonal Wetland SW-07 0.05

Seasonal Wetland SW-08 0.01

Seasonal Wetland SW-09 <0.01

Seasonal Wetland SW-10 <0.01

Seasonal Wetland SW-11 0.05

Seasonal Wetland SW-12 0.02

Seasonal Wetland SW-13 <0.01

Seasonal Wetland SW-14 <0.01

Seasonal Wetland SW-15 0.04

Seasonal Wetland SW-16 0.36

Seasonal Wetland SW-17 0.05

Seasonal Wetland SW-18 0.01

Seasonal Wetland SW-19 0.02

Seasonal Wetland SW-20 0.06

120 0 12060

BM-03

BM-04

BM-06

BM-05

BM-07BM-08

BM-09

BM-10

NTSM-09

NTSM-10

NTSM-15

NTSM-16

NTSM-17

NTSM-11

NTSM-13

NTSM-14

NTSM-12

NTSM-18

NTSM-19

SW-41

SW-40

SW-29

SW-42

SW-39

SW-28

SW-38

SW-26

SW-33

SW-27

SW-32

SW-34

SW-25

SW-43

SW-30

SW-35

SW-36

SW-37

SW-44

SW-24

SW-46

SW-45

SW-47

SW-48

SW-23

SW-22

SW-50

SW-49

SW-51

SW-21

SW-52

SW-31

SW-53

SW-54

SW-55

SW-56

SW-57

SW-58

SW-59

PP-6a

PP-6b

PP-7a

PP-6c

PP-7b PP-7c

PP-8a

PP-8b

PP-8c

SP-12

SP-13

SP-14

SP-15

SP-16

SP-17

SP-18

SP-19

SP-20

37.4623438, -122.11818811

N

P ro je ct s4

\4

-0

\0

\R e p o rt s\

W e tla n d D e lin e a tio n

\W e tla n d D e lin e a tio n

.a p rx

Figure 7c. Preliminary Identification of Potential Section 404/401 Jurisdictional Wetlands

Palo Alto Municipal Golf Course Reconfiguration Project - Wetland Delineation Report (4821-02) June 2025

Study Area

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 Points

Sample Points

Section 404/401 Jurisdictional Wetlands

Brackish Marsh (0.13 ac)

Non-Tidal Salt Marsh (5.83 ac)

Seasonal Wetland (2.53 ac)

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

Prepared for City of Palo Alto June 14

Imagery: Google Earth, February 2024

Wetland Type Label Acres Wetland Type Label Acres

Brackish Marsh BM-03 0.01

Brackish Marsh BM-04 0.01

Brackish Marsh BM-05 0.01

Brackish Marsh BM-06 0.01

Brackish Marsh BM-07 0.02

Brackish Marsh BM-08 0.02

Brackish Marsh BM-09 0.02

Brackish Marsh BM-10 0.01

Non-Tidal Salt Marsh NTSM-09 0.52

Non-Tidal Salt Marsh NTSM-10 0.21

Non-Tidal Salt Marsh NTSM-11 0.04

Non-Tidal Salt Marsh NTSM-12 0.02

Non-Tidal Salt Marsh NTSM-13 0.02

Non-Tidal Salt Marsh NTSM-14 1.54

Non-Tidal Salt Marsh NTSM-15 0.7

Non-Tidal Salt Marsh NTSM-16 0.16

Non-Tidal Salt Marsh NTSM-17 0.71

Non-Tidal Salt Marsh NTSM-18 0.3

Non-Tidal Salt Marsh NTSM-19 0.12

Seasonal Wetland SW-21 0.1

Seasonal Wetland SW-22 <0.01

Seasonal Wetland SW-23 0.01

Seasonal Wetland SW-24 0.01

Seasonal Wetland SW-25 <0.01

Seasonal Wetland SW-26 <0.01

Seasonal Wetland SW-27 0.01

Seasonal Wetland SW-28 0.05

Seasonal Wetland SW-29 0.14

Seasonal Wetland SW-30 0.22

Seasonal Wetland SW-31 0.16

Seasonal Wetland SW-32 <0.01

Seasonal Wetland SW-33 <0.01

Seasonal Wetland SW-34 0.02

Seasonal Wetland SW-35 0.01

Seasonal Wetland SW-36 <0.01

Seasonal Wetland SW-37 0.05

Seasonal Wetland SW-38 <0.01

Seasonal Wetland SW-39 <0.01

Seasonal Wetland SW-40 <0.01

Seasonal Wetland SW-41 <0.01

Seasonal Wetland SW-42 <0.01

Seasonal Wetland SW-43 0.28

Seasonal Wetland SW-44 0.16

Seasonal Wetland SW-45 0.01

Seasonal Wetland SW-46 0.01

Seasonal Wetland SW-47 0.01

Seasonal Wetland SW-48 <0.01

Seasonal Wetland SW-49 <0.01

Seasonal Wetland SW-50 0.01

Seasonal Wetland SW-51 <0.01

Seasonal Wetland SW-52 0.01

Seasonal Wetland SW-53 <0.01

Seasonal Wetland SW-54 0.01

Seasonal Wetland SW-55 0.13

Seasonal Wetland SW-56 0.01

Seasonal Wetland SW-57 0.01

Seasonal Wetland SW-58 0.01

Seasonal Wetland SW-59 <0.01

120 0 12060

Project Wetland Delineation Report 23 H. T. Harvey & Associates

3.1.2 Precipitation Data

The survey took place in the spring of 2025. Relative to the 30-year climate normal (15.53 inches annually), precipitation in the study area was slightly lower than the normal range of precipitation for the 12-month period leading up to the delineation. Total precipitation recorded in the area from April 2024 through March 2025 was

13.29 inches, which is approximately 86% of the 30-year average (1991–2020) for that same time period (PRISM Climate Group 2025).

Conditions were considered to be normal for all site visits according to the analysis provided by the USACE’s Antecedent Precipitation Tool, which compares antecedent precipitation from a regional network of weather stations to the 30-year normal range (see Appendix G, Antecedent Precipitation Tool output). These conditions were considered when assessing the biotic habitats present within the study area.

A table showing the results of the Antecedent Precipitation Tool is included as Appendix G.

3.1.3 Site Conditions and Observations

The study area consists of narrow ditches and broad, relatively level depressions with gradual to moderately steep slopes adjacent to neighboring fairways, golf greens, bunkers, concrete golf cart paths, and maintenance roads. The ditches vary in length throughout the study area (approximately 83–300 feet long). The depressions are irregularly shaped and range in size from approximately 18–400 feet in width by 270–770 feet in length.

Features within these ditches and depressions include terraces (from approximately 5–60 feet wide), raised berms (approximately 1 foot in height), and unofficial pathways. The golf course surrounding the study area is higher in elevation than the study area, with topographic variation due to various on-site amenities.

In general, the depressions and ditches have wetter conditions than the slopes and terraces within the study area. For example, at the time of the survey, small portions of the depressions and most ditches were observed to either have saturated soil and/or small pools of standing water. In contrast, no saturation or standing water was observed along the slopes or terraces within the study area. The study area’s hydrology is primarily influenced by precipitation. Precipitation runoff from the golf course is directly transported to and among the depressions and ditches from the golf course through pipes (approximately 4 inches to 1.5 feet in diameter).

Some of the depressions drain to a managed pump station near the Palo Alto Municipal Airport which ultimately discharges into the San Francisco Bay. Additionally, precipitation runoff flows directly from the adjacent golf course areas to the study area because the study area is lower in elevation than the adjacent golf course areas. Other hydrological drivers that contribute to the study area’s hydrology include shallow groundwater. The golf course sprinkler system may have a minimal influence on the study area’s hydrology.

Hydrology monitoring performed by H. T. Harvey & Associates in 2024 indicated that while the amount of ponded surface area within the study area remained relatively consistent between February–April, on May 1, 2024, the amount of ponding and soil saturation was observed to have decreased moderately, and portions of the study area had dried up. Because the golf course sprinkler system input is presumed to occur throughout the year, these fluctuating levels of ponding and soil saturation indicate that irrigation input is not a driving

Project Wetland Delineation Report 24 H. T. Harvey & Associates factor of the study area’s hydrology. The depressions and ditches are generally occupied by herbaceous wetland vegetation at lower elevations, and ruderal upland vegetation at higher elevations.

3.1.4 Rationale for Sample Point Choice

Twenty-two sample points were selected to document conditions in representative jurisdictional areas (Figures 7a–c; Appendix C). Rationale and findings for wetland data form sample point locations are summarized in Table 5.

Table 5. Summary of Sample Point Locations and Results

Name Sampling Rationale Hydrophytic Vegetation?

Hydric Soil?

Wetland Hydrology? Overall Wetland Assessment

SP-1 Revisited 2024 sample point:

47EXP (Appendix D); point taken to characterize seasonal wetland.

Yes Yes Yes This area is a three-parameter wetland.

SP-2 Upland paired point to

SP-1.

No No Yes Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-3 Sampled in questionable upland area dominated by Italian rye grass (Festuca perennis); sample point taken to characterize seasonal wetland habitat. Yes

Yes Yes This area is a three-parameter wetland. Hydric soils presumed due to the presence of hydrophytic vegetation and wetland hydrology. Sample point is also located on a concave surface and within a relatively recently developed (expanded) wetland, constructed ~9 years ago.

SP-4 Upland paired point to SP-3 and SP-5.

No No No Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-5 Sample point taken to characterize non-tidal salt marsh habitat.

Yes Yes Yes This area is a three-parameter wetland.

SP-6 Sample point taken to characterize seasonal wetland habitat dominated by seaside barley (Hordeum marinum).

Yes Yes Yes This area is a three-parameter wetland.

SP-7 Upland paired point to

SP-6.

No No No Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-8 Revisited 2024 sample point:

59EXP (Appendix D); point taken to characterize non-tidal salt marsh habitat

Yes Yes Yes This area is a three-parameter wetland.

Project Wetland Delineation Report 25 H. T. Harvey & Associates

Name Sampling Rationale Hydrophytic Vegetation?

Hydric Soil?

Wetland Hydrology? Overall Wetland Assessment

SP-9 Upland paired point to

SP-8.

No Yes Yes Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-10 Sample point taken to characterize brackish marsh habitat edge

Yes Yes Yes This area is a three-parameter wetland.

SP-11 Upland paired point to

SP-10.

No No No Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-12 Sample point collected in 2024 (8ENH) was revisited (Appendix D); point taken to characterize non-tidal salt marsh

Yes Yes Yes This area is a three-parameter wetland.

SP-13 Upland paired point to

SP-12.

No Yes No Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-14 Sample point collected in 2024 (39EXP) was revisited (Appendix D); point taken to characterize non-tidal salt marsh

Yes Yes Yes This area is a three-parameter wetland.

SP-15 Upland paired point to

SP-14.

No No No Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-16 Sample point collected in 2024 (36EXP) was revisited (Appendix D); point taken to characterize non-tidal salt marsh

Yes Yes Yes This area is a three-parameter wetland.

SP-17 Upland paired point to

SP-16.

No Yes Yes Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-18 Sample point collected to characterize non-tidal salt marsh habitat

Yes Yes Yes This area is a three-parameter wetland.

SP-19 Upland paired point to SP- 18 and SP-20.

No Yes Yes Upland; this area does not meet the three-parameter USACE wetland criteria.

SP-20 Sample point collected to characterize non-tidal salt marsh habitat

Yes Yes Yes This area is a three-parameter wetland.

SP-21 Sample point collected to characterize beardless wild rye (Elymus triticoides) and Italian rye grass dominated slope

Project Wetland Delineation Report 26 H. T. Harvey & Associates

Name Sampling Rationale Hydrophytic Vegetation?

Hydric Soil?

Wetland Hydrology? Overall Wetland Assessment

SP-22 Sample point collected to characterize seasonal wetland habitat

3.1.5 Photo Points

Photo point labels, coordinates, and rationales for photo documentation are presented in Table 6 and depicted on Figures 7a–c. Photos are presented in Appendix E.

Table 6. Coordinates and Rationale for Photo Points

Label Latitude, Longitude Depiction

Photo 1 37.45577268, -122.11786542 Representative Photograph of Seasonal Wetland (Midground) and Ruderal Upland (Foreground) in the Southern Portion of the Study Area (Photo Point 1). View of SW-02 to the South.

Photo 2 37.45769287, -122.11665842 Representative Photograph of Seasonal Wetland (Midground, Center) Adjacent to a Raised Berm with Ruderal Upland (Left) in the Southeastern Portion of the Study Area (Photo Point 2). View of SW-05 to the Southeast.

Photo 3 37.45886775, -122.11750071 Representative Photograph of Ruderal Upland (Foreground), Seasonal Wetland (Midground, Right), Non-Tidal Salt Marsh (Midground, Left), and Raised Berm with Seasonal Wetland and Ruderal Upland (Midground, Center) in the Southeastern Portion of the Study Area (Photo Point 3). View of SW-07, NTSM-03, and NTSM-02 to the Southeast.

Photo 4a 37.45789733, -122.11604632 Representative Photograph of Ruderal Upland (Foreground), Seasonal Wetland (Midground) and Non- Tidal Salt Marsh (background) in the Eastern Portion of the Study Area (Photo Point 4a). View of SW-16 and NTSM-04 to the Northeast.

Photo 4b 37.45789733, -122.11604632 Representative Photograph of Seasonal Wetland (Midground) and Ruderal Upland (Foreground) in Eastern Portion of Study Area (Photo Point 4b). View of SW-16 to the Southwest.

Photo 5 37.46078, -122.11764 Representative Photograph of Brackish Marsh (Midground), Seasonal Wetland (Foreground), and Ruderal Upland (Right) in the Northern Portion of the Study Area (Photo Point 5). View of SW-19, BM-01, and NTSM-08 to the East.

Photo 6a 37.46043085, -122.1199621 Representative Photograph of Ruderal Upland (Left), Seasonal Wetland (Center), and Non-Tidal Salt Marsh (Right) in the Central Portion of the Study Area (Photo Point 6a). View of SW-43 and NTSM-17 to the South.

Photo 6b 37.46043085, -122.1199621 Representative Photograph of Ruderal Upland (Foreground), Seasonal Wetland (Midground) and Non-

Project Wetland Delineation Report 27 H. T. Harvey & Associates

Label Latitude, Longitude Depiction Tidal Salt Marsh (Background) in the Central Portion of the Study Area (Photo Point 6b). View of SW-43 and NTSM-17 to the West.

Photo 6c 37.46043085, -122.1199621 Representative Photograph of Ruderal Upland (Right), Seasonal Wetland (Center), and Non-Tidal Salt Marsh (Left) in Central Portion of Study Area (Photo Point 6c).

View of SW-46 and NTSM-17 to the North.

Photo 7a 37.45953782, -122.12212166 Representative Photograph of Developed/Ruderal Upland (Right), Seasonal Wetland (Center) and Non-Tidal Salt Marsh (Left) in the Western Portion of the Study Area (Photo Point 7a). View of SW-29 and NTSM-09 to the Northwest.

Photo 7b 37.45953782, -122.12212166 Representative Photograph of Ruderal Upland (Foreground), Seasonal Wetland (Midground), and Non- Tidal Salt Marsh (Background) in the Western Portion of the Study Area (Photo Point 7b). View of SW-29 and NTSM-09 to the Southwest.

Photo 7c 37.45953782, -122.12212166 Representative Photograph of Ruderal Upland…