Scope_for_Wetland_Mitigation.docx

Background The City of Palo Alto completed construction of the Palo Alto Municipal Golf Course Reconfiguration Project in 2017 following a flood protection project on San Francisquito Creek that impacted the golf course. The Golf Course, now the Baylands Golf Links, is located within the Palo Alto Baylands at 1875 Embarcadero Road in Palo Alto, California.

The reconfiguration project resulted in 0.29 acres of temporary and 1.36 acres of permanent impacts to wetlands/waters of the United States and State. The project’s permits (Attachment A) and Mitigation and Monitoring Plan (Attachment B) require at least 4.0 ac of on-site wetland expansion (i.e., wetland creation) and 0.20 ac of on-site wetland enhancement to compensate for the project’s impacts (ICF International 2016).

The plan to expand and enhance the project wetlands is provided in the project’s Mitigation and Monitoring Plan (MMP). The plan included 8.03 ac of wetland expansion and 0.42 of enhancement of existing wetlands at the golf course project site, exceeding the minimum permit required mitigation acreage by 100%. The RWQCB permit states (on Page 4) that, “Of the 8.03 acres of wetlands that the Applicant proposes to expand and the 0.42 acres that the Applicant proposes to enhance, 4 acres of expansion and 0.20 acres of enhancement are required to compensate for the Project’s impacts to waters of the State. Additional acres of expanded or enhanced wetlands may be used to provide for any additional mitigation required by Condition 33.”

The City implemented grading and planting to expand and enhance the wetland habitat in 2016 and 2017. Wetland expansion included excavating fill from elevated terrain surrounding existing wetlands, while wetland enhancement included invasive species removal. Both expanded and enhanced wetlands were then hydroseeded and planted with native brackish marsh plant species such as brown-headed rush (Juncus phaeocephalus), slough sedge (Carex obnupta), meadow barley (Hordeum brachyantherum), alkali barley (Hordeum depressum), and common spikeweed (Centromadia pungens). The project’s permits and MMP call for a minimum of 5 years of habitat monitoring of the expanded and enhanced wetlands. Since the wetland expansion/enhancement occurred in 2016 and 2017, mitigation monitoring was required in 2017 through 2021.

While the correct acreage of wetlands was constructed, the maintenance and monitoring necessary to attain performance standards was not completed. Per Condition 33 of the RWQCB permit, the amount of mitigation required increases by 10% for each year that successful implementation of mitigation was deferred.

The City has been in communication with the RWQCB and is working diligently to get the project into compliance. The following documents have been submitted to the RWQCB and are attached as reference to this RFP.

· Palo Alto Municipal Golf Course Reconfiguration Project Wetland Mitigation Condition Assessment Report (H.T. Harvey & Assoc., August 2024) (Attachment C)

· Palo Alto Municipal Golf Course Reconfiguration Project Wetland Delineation Report (H.T. Harvey & Assoc., June 2025) (Attachment D)

· Palo Alto Municipal Golf Course Reconfiguration Project Remedial Wetland Mitigation Plan (H.T. Harvey & Assoc., September 2025) (Attachment E)

Remedial Actions Several remedial actions have been completed, or are planned, to increase the cover and diversity of native hydrophytic species and to increase the probability that success criteria will be met. These include:

· trail decommissioning through wetlands,

· removal of invasive plant species,

· hydrologic modifications to drains present in some wetlands, and

· revegetation to increase wetland species richness and native wetland cover, including:

· Seeding with native wetland seed,

· Revegetation with container plants (native plant species) in expanded and enhanced wetland areas.

The revegetation will occur over a two-year timeframe. In 2025, 0.3 acres will be revegetated – 0.2 acres with seed and 0.1 acres with container plants. In 2026, an additional 0.3 acres will be revegetated with either seed, container plants, or a combination depending on success of the revegetation effort in 2025.

Mitigation Monitoring Plan This scope consists of CONSULTANT providing the CITY with professional services for the monitoring and reporting of wetland mitigation associated with the City of Palo Alto Golf Course Reconfiguration Project. The scope of services includes, but is not limited to, wetland mitigation monitoring and annual reporting for a period of five years, or until success criteria are met and the RWQCB has indicated in writing that the City’s mitigation obligations have been met. It is understood that all monitoring and reporting services shall be conducted in compliance with applicable environmental regulations and permit requirements, MMP and revisions to the MMP.

The monitoring methods are based on the project’s Mitigation and Monitoring Plan (MMP; ICF International 2016) and revised monitoring methodology approved for the project by RWQCB in 2024 and as described in Section 4-Monitoring and Adaptive Management of the Remedial Wetland Mitigation Plan.

Scope of Work

TASK 1: PROJECT MANAGEMENT AND COORDINATION

A. Project initiation meeting B. Annual pre-monitoring kick-off meeting C. Review meeting to discuss results of annual monitoring and recommendations

TASK 2: MONITORING

Monitoring of the two different types of mitigation wetland, expanded and enhanced, will be monitored and analyzed separately. Monitoring for both types will occur in the spring of each calendar year, in March through May, dependent on rainfall.

A. BIOLOGICAL - Successful establishment of wetland vegetation will be based on health and vigor of native, hydrophytic wetland species, absolute percent cover of both native, hydrophytic and invasive species, and native plant species richness. The methodology for absolute cover, health and vigor, and species richness described in September 2025 Monitoring and Adaptive Management (Section 4) of the Remedial Wetland Mitigation Plan shall be used.

B. NATURAL RECRUITMENT – Natural recruitment will be recorded each monitoring year.

C. HYDROLOGIC MONITORING – The extend and duration of ponding will be monitored for the first three years of the monitoring period in wetland groups two and six. A qualified restoration ecologist will provide guidance and recommendations to the City to potentially adjust the drain modifications.

D. PASPALUM MONITORING - The distribution of Paspalum will be assessed by a qualified restoration ecologists within the 10-foot buffer around the 8.48 ac wetlands. Any location where Paspalum turf has invaded the 10-foot buffer will be mapped during annual monitoring.

E. PHOTO DOCUMENTATION – Annual color photos will be taken from the photo-documentation locations shown in Figure 2 and Appendix B of the Remedial Wetland Mitigation Plan.

TASK 3: DATA ANALYSIS

Data analysis will be conducted as soon as possible following monitoring and collection of field data. Data analysis will be conducted using standard spreadsheet, database, and statistical computer applications. Data input will be spot-checked and results reviewed by a restoration ecologist or consultant project manager.

Annual monitoring results will be compared with results from previous years to evaluate site progress.

TASK 4: ANNUAL REPORTING

Consultant shall prepare an annual monitoring report that adheres to the monitoring and reporting methods described in Task 2, and in Section 4 of the Remedial Wetland Mitigation Plan (H.T. Harvey & Assts., September 2025) to the City by September 1 of each calendar year with the first report due September 1, 2026. The City will review and the final report will be transmitted by the City to the Regional Water Quality Control Board by December 31.

Annual monitoring reports will be prepared by the restoration ecologist responsible for monitoring. Pursuant to the U.S. Army Corps of Engineers South Pacific Division Mitigation Guidelines, the annual report will include the following components.

· A vicinity map and a compensatory mitigation map.

· A description of the restoration site's location and characteristics, including a summary of the restoration effort.

· A discussion of the previous year's management efforts.

· A summary of the monitoring methods and discussion of any modifications made to the monitoring methods since the previous year.

· A summary of the results of the biological performance criteria monitoring and supporting data included as an appendix.

· A summary of the results of the hydrologic and salinity monitoring.

· A summary of the Paspalum TE turf monitoring.

· A discussion of remedial measures identified and implemented during the previous year and a summary of the effectiveness of the remedial measures that were implemented.

· Adaptive management recommendations, including discussion of any concerns or areas of inadequate performance and recommendations for remedial actions.

· Mitigation treatments: photo and other monitoring locations.

TASK 5: ADDITIONAL SERVICES

Additional services could include implementation of additional remedial actions recommended by Consultant’s Restoration Ecologist to increase likelihood of meeting project success criteria at the end of the monitoring period. This could include invasive species removal, seeding or planting native container plants, or hydrologic modifications.

ATTACHMENTS

ATTACHMENT A: Water Quality Certification for the City of Palo Alto Municipal Golf Course Reconfiguration Project, June 22, 2016 ATTACHMENT B: Golf Course Reconfiguration Project Mitigation and Monitoring Plan . ICF International, June 14, 2016 ATTACHMENT C: Palo Alto Municipal Golf Course Reconfiguration Project Wetland Mitigation Condition Assessment Report (H.T. Harvey & Assoc., August 2024) ATTACHMENT D: Palo Alto Municipal Golf Course Reconfiguration Project Wetland Delineation Report (H.T. Harvey & Assoc., June 2025) ATTACHMENT E: Palo Alto Municipal Golf Course Reconfiguration Project Remedial Wetland Mitigation Plan (H.T. Harvey & Assoc., September 2025)